在一些实际案例中,税务机关对能否将核定税款作为对纳税人予以偷税处罚的数额依据心存疑虑,尽管在理论上既有肯定说、又有否定说,但在实践中税务机关大多持否定说。本文并未对该问题作全面的分析,而只是从法律解释的角度,紧扣有关法律法规,论证了应纳税款、核定税款与偷税数额之间的关系,从而支持了肯定说的观点。 In some practical cases, the tax authorities have doubts as to whether the approved tax payment can be tax-evasion based on the amount of tax evasion. Although in theory there are affirmations and denials, most tax authorities in practice Negative to say. This article does not give a comprehensive analysis of the issue, but only from the perspective of legal interpretation, closely linked to relevant laws and regulations, demonstrate the tax liability, the relationship between the approved tax and the amount of tax evasion, thus supporting the affirmative point of view.