The costs of appeal are assessed against the Plaintiff.

1. Regarding ground of appeal No. 1

A. Before Article 1(1)1 of the former Income Tax Act (Amended by Act No. 9897, Dec. 31, 2009) and the former Income Tax Act (Amended by Act No. 12852, Dec. 23, 2014)

B. The Plaintiff’s income tax is calculated by adding up each of the above former Income Tax Act.

Article 1-2(1)1 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 22034, Feb. 18, 2010; Presidential Decree No. 26067, Feb. 3, 2015) provides that “A resident means a person who has a domicile in the Republic of Korea or a temporary domicile in the Republic of Korea for at least one year.”

F. The Enforcement Decree of the Income Tax Act by adding each of the above Enforcement Decree to the Income Tax Act

Article 2(1) provides that “The address shall be determined based on the objective facts of living relationship, such as the existence of a family living together in Korea and of assets located in Korea,” and Article 2(3)2 provides that “When a family living together in Korea and a family living together in Korea is deemed to continue to reside in Korea for not less than one year in view of his occupation and property status, the address shall be deemed to have the domicile in Korea.” Meanwhile, Article 2(4)1 provides that “when a family living in Korea is deemed to have an occupation ordinarily required to reside in Korea for not less than one year,” it shall be deemed to have no domicile in Korea. The lower court recognized the facts as indicated in its reasoning after comprehensively taking into account the adopted evidence. The lower court recognized the facts as indicated in its reasoning. The Plaintiff was registered with his spouse in Korea from 2007 to 2010, and the Plaintiff was staying 188 days annually with his/her average resident registration in Korea, and

The plaintiff does not own tangible assets, while it owns a number of real estate in Korea, and the plaintiff is Spodi in Korea.