Zeroing out the deadlines for a tax audit: a constitutional and legal test

This article discusses the problem of calculating deadlines in tax relations. The problem is considered on the example of a case that reached the Constitutional Court of the Russian Federation. The author believes that the legal positions of the Constitutional Court, which considered the term as, on the one hand, a guarantee of the taxpayer's rights, and on the other, the limits of the restriction of his rights allowed by law, have a broader meaning than the motivation for a specific legal problem.