As stipulated in Article 39 of the Tax Collection Act, a case may not be referred for compulsory enforcement for the time being if the taxpayer provides collateral equal to one third of the taxable amount decided following the recheck or equivalent collateral, or if the tax authority prohibits disposal of the property that equals the taxable amount decided following the recheck. However, a taxpayer is not required to pay a fine first if he submits an administrative appeal against the decision made by the tax authority regarding the fine and the fine is not subject to compulsory enforcement before the administrative remedy procedure is concluded, as set forth in Article 50-2 of the same act.