He also notes that it is most often small and medium enterprises (SMEs) whose rights are infringed upon in the tax arena, the reason being that smaller companies 'administrative systems are often not very sound, so that oversights easily occur in their tax filings. If the tax authorities interpret the law incorrectly or the Administrative Court makes rulings which violate the Constitution, the firms' rights are likely to suffer.
他並且指出，通常會在稅務上遭受權利侵害的，以中小企業居多，原因在於中小企業通常體質較不健全，容易出現稅務上的疏忽，而當行政機關解釋不當或行政法院判例違憲時，權利就容易受到侵害。