随着实践的发展和理念的更新,协调和解作为解决税务行政诉讼纠纷的方式已经有了一定的理论基础。这主要表现为协商民主的理念渗入到税务行政领域和司法程序中、税务机关自由裁量权的普遍存在、涉税争议涉及的客观事实还原的困难以及税收法律关系具有平等性等四个方面。 With the development of practice and the renewal of the concept, the reconciliation and reconciliation already have certain theoretical basis as the way to settle the dispute of the tax administrative litigation. This is mainly manifested in four aspects: the concept of consultative democracy has infiltrated into the field of tax administration and judicial procedures, the prevalence of discretion of tax authorities, the objective factual reduction involved in tax-related disputes, and the equality of tax laws.