According to agency theory, the government and business enterprises have different interests in paying taxes. The motivation for using deferred tax asset and liability to identify earnings management is that there is usually more discretion in generally accepted accounting principles than in tax laws. Managers may have an incentive to increase income in the financial statements without increasing income in the tax report. A possible reason why managers do not want to increase taxable income is that this will lead to an increase in tax costs. Therefore, one of the things that probably affects the earnings management is deferred taxes.   The aim of the research is to investigated whether the deferred taxes resulting from the financial statements reported based on accounting standard 35 as a strategy for managers to achieve earnings management or not. To achieve the goal of the research, the data of 169 sample companies from the Tehran Stock Exchange, were collected using the systematic elimination approach and were analyzed using the method of descriptive-correlation analysis by performing logistic regression test. The findings showed that the deferred tax assets have an effect on earnings management, but deferred tax liabilities have no effect on earnings management. The obtained results indicate that managers use deferred tax assets to manipulate earnings.

According to the rules of jurisprudence, any damage caused by any person to another must be compensated. The narrations indicate that the Islamic State is obliged to compensate the damages caused by its agents to the others. However, Direct taxes Act considers any damages resulting from the intention, negligence and oversight of tax officials to be subject to civil liability. This approach does not match with the serious occupation of these agents and the auditing principles. Due to the fact that it is impossible to review all tax documents of business units in auditing and today reviewing all documents is an unprofessional act, so tax auditors are exposed to risks. On the other hand, tax officials face a lot of legal questions. Violation of the directives and opinions of the Supreme tax Council by the Court of Administrative Justice and the weak legal structure of the tax Affairs Organization, deprive the possibility of creating a clear procedure in legal affairs and create many ambiguities for tax officials. And they have remained accountable, accordingly, to the taxpayers, civil liability based on some kind of fault in cases of malice, unforgivable negligence, and disregard to the explicit text of the law is appropriate.

Abstract According to Article 198 of the Direct taxes Act, in commercial companies, company managers, collectively or individually, are jointly and severally responsible to the company for paying the company's income tax that has been final during their management. Based on the principle of the independence of the legal personality of the managers from the company, the debt of the company can only be claimed from the company itself, as a result, claiming the company's tax debt from the managers is against the aforementioned legal principle. On the other hand, according to the principle of personal tax responsibility, tax can only be claimed from the taxpayer, i.e. the company. Article 198 is written in such a way that the joint and several liability of directors is general, absolute, and as a result includes all members of the board of directors, including the signatory directors and others, as well as those who are faulty or not faulty of non-payment of taxes. Since the ruling on the personal responsibility of managers for company tax is against the principles governing corporate law, obligation law, and tax law, as well as restricting the individual rights of board members and the CEO of the company, the legal analysis of this issue in the framework of the concepts and principles of the legal system in related fields can reveal new angles about the basics of managers' responsibility for corporate taxes and appropriate legal policy in this matter. The issue that can be raised is whether the provision of Article 198 of the Act is justified from a legal point of view or not. Is it justifiable to impose personal responsibility on managers for company taxes, based on the principles of tax law, obligation law,corporate law, and other related legal fields? What is the ideal legal system for the legal regulation of managers' responsibility for corporate taxes? The theoretical framework of the research is based on several principles and accepted in related legal fields, including the principle of independence of the legal personality of managers from the company, the principle of individuality of tax, the principle of individuality of responsibility, the principle of the ability to pay taxes, the principle of tax justice, the principle of ease of tax collection, The principle of guaranteeing public rights, the moral principle of responsibility, and other relevant principles, and a balance between these principles are organized. The sources of this research are derived from legal principles and principles in related fields, fundamental principles, and the subject of legal consensus, including justice and individual rights, relevant laws and regulations, as well as relevant and useful findings in comparative law. The research method in this article is comparative and the validation of Article 198 of the Act is analyzed, reasoned, and deduced based on the criteria derived from certain legal principles in related legal fields including tax law, corporate law, public law, and civil liability law. This article tries to prove the hypothesis with legal analysis that the imposition of such responsibility is unjustified and incompatible with the foundations, principles, and integrity of the legal system. Based on the research conducted in this article, the joint and several liability of managers for company tax, which is very strict against managers to facilitate tax collection and deal with any possibility of tax abuse, regardless of the manager's role, authority, and ability to not pay tax. The imposed tax is contrary to the desired legal and tax system and is a clear violation of individual rights and the extensive and unjustified use of public law tools. The main objection is that Article 198 sacrifices the role of fairness, justice, individual rights and freedoms, the moral aspects of the legal system, and the integrity of the legal system without providing the necessary justifications and bases for the expediency of providing tax revenue for the government. From the point of view of this research, the ideal legal system for defining the responsibility of managers for corporate taxes is the civil liability system, which uses legal and acceptable elements and takes into account effective factors such as the manager's obligation to pay the company tax, the manager's fault in paying the tax, The role and authority of the manager in paying taxes, the presence or absence of sufficient resources in the company to pay taxes and other responsibility factors, to establish a fair and efficient system.

The abolish themselves are skeptical about the capacity of criminal justice for crime control and believe that as long as there are easier and more human ways to control crime, punishment should not be used as a weapon in the first place. Abolitionism doctrine maintains that the formal system of criminal justice, not is less effective in the prevention of recidivism, but also criminogenic and label of crime causing him to commit crime again. Therefore, they advocates the non-interference of criminal law or, if it is investable, a minimal involvement in the process of trial. The findings of abolitionism in the criminal policy of different countries gave rise to decriminalize, depenalization and diversion. deferred prosecution or non- prosecution is also a new concept in criminal procedure that is consistent with non-intervention criminal policy. This policy was proposed because of the failure of the traditional repressive approach of prosecution. Adversarial prosecution, judicialization and acceleration of prosecution, reduction in criminal population and regarding human dignity, selective prosecution of accuses are among the important consequences of the deferred prosecution. This article attempts to express concept and foundations of the deferred prosecution and investigates its manifestations in the Iranian criminal policy.

In order to stop reliance on the oil economy and finance the yearly budget of the country, safeguarding tax revenues and benefitting from them are ever the more necessary. tax evasion is thus criminalized not only in Iran but also in most countries. However, the criminal strategy can only be effective if it is properly developed and implemented. The amendment of the Direct tax Law in 1394, brought about a better level of performance from Iranian legislators in comparison to their performance on previous regulations. Also, by expanding the criminal scope of tax evasion, more activities were categorized as tax evasion, but this approach was not formulated in a way that would act as a powerful and deterrent tax evasion strategy. Hence, the use of disproportionate financial penalties, the lack of legal consequences for those attempting to evade taxes, the lack of explicit and general legal consequences and penalties for conspiring to evade taxes, and the lack of specification of the prosecution and investigation stages are only part of the most important holes within the Iranian legislative system against tax evasion. On the other hand, the Canadian Legislative System has adopted a better criminal justice policy in aspects of criminalization, penalization, and specialization in criminal proceedings to counter tax evasion. Therefore, this paper intends and aims to draw up and recommend a preventative and effective tax evasion strategy by analyzing and comparing the penal rules of Iran and Canada.

The notion of statistical convergence has fascinated many researchers due mainly to the fact that it is more general than the well-established hypothesis of ordinary (classical) convergence. This work aims to investigate and present (presumably new) the statistical versions of deferred weighted Riemann integrability and deferred weighted Riemann summability for sequences of fuzzy functions. We first interrelate these two lovely theoretical notions by establishing an inclusion theorem. We then state and prove two fuzzy Korovkin-type theorems based on our proposed helpful and potential notions. We also demonstrate that our results are the nontrivial extensions of several known fuzzy Korovkin-type approximation theorems given in earlier works. Moreover, we estimate the statistically deferred weighted Riemann summability rate supported by another promising new result. Finally, we consider several interesting exceptional cases and illustrative examples supporting our definitions and the results presented in this paper.