The system of unexpired statute of limitations has not been unificated in the area of pubic law, the logically coherent arguments at judicial practice and theory believe that, it is suitable to analogy related stipulation in civil law. Although, in the matter of interpretation not all matters of unexpired statute of limitations in civil law could be adopted in the situation of pubic law. And from the point of view below the rule of law, principles of administration according to law, democracy, stability of law, protection of reliance and equality, the unexpired statute of limitations should be legally defined. The Research about examples of § 53 Federal Administrative Procedure Law and §§ 171; 230 General Tax Law in Germany, beside the analoging to suitable related stipulation in civil law, we need to consider both the period of Administrative investigation before leving tax and the period of Administrative relief after leving tax to canceling the leving, as the matter of unexpired statute of limitations, and to explain the reason. It also criticizes the opinion of administrative court judgment, and it is necessary to change matters of suspended statute of limitations to matters of unexpired statute of limitations, so that in the future we can avoid abusing authority of the administrative organizations.