종합소득세부과처분취소
1. All appeals filed by the plaintiffs are dismissed.
2. The costs of appeal are assessed against the Plaintiffs.
The purport of the claim and appeal is the purport of the appeal.
1. The reasons for the court's explanation concerning this case are as follows: each "Article 143" of the 4th, 11, and 6th, 21th, of the first instance judgment; each "Article 143" of the 5th, 3, and 8th, and the "Enforcement Decree of the Income Tax" of the 7th, 20 or 21th, respectively; each "the plaintiff" of the 8th, 8th, and "the plaintiff" of the 8th, as "the plaintiff," and the 8th, are the same as the reasons for the first instance judgment, except for the additional determination as to the allegations emphasized by the plaintiffs in this court pursuant to Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.
2. Additional determination
A. Whether the Plaintiffs’ business commencement date should be deemed to be the Plaintiffs’ “business commencement date” in 2015 under the principle of no taxation without the law, barring any special circumstance, the tax laws should be interpreted in accordance with the statutory text, and shall not be extensively interpreted or analogically interpreted without reasonable grounds. However, even according to the language and text of the tax laws itself, if their meaning is unclear or if it appears to be contrary to or conflict between the external laws and regulations, the court must naturally state the true meaning of the language and text at issue through harmonious interpretation between the laws and regulations. In this case, it is inevitable for a judge to conduct the combined interpretation of the laws and regulations within the scope that does not undermine the legal stability and predictability pursued by the principle of no taxation without the law (see, e.g., Supreme Court Decisions 2007Du4438, Feb. 15, 2008); Article 1-2(1)5, Article 19(1), Article 2(1), Article 2(1), Article 38(1), Article 48(1), Article 5(1)4)1 of the former Enforcement Decree.