Taxpayers Cannot Be Required To Pay Attorney Fees

In recent times, Federal, State and Municipal governments have been frequently launching incentivized debt installment payment programs. Those programs offer attractive benefits to taxpayers that abandon administrative and legal proceedings. In exchange, they obtain significant reductions in interest and fine for payment of tax debts as well as attorney's fees payable for abandonment of the legal proceedings.

However, it is not uncommon, especially where the tax debts are the subject matter of legal actions brought by taxpayers, namely actions for annulment, that the National Treasury demands the payment of attorney fees both in installment payment programs and in legal actions taxpayers are required to abandon in order to join the program.