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(영문) 대구고등법원 2018. 05. 18. 선고 2017누6229 판결

전심절차를 거치지 않은 항고소송은 부적법함[국승]

Case Number of the immediately preceding lawsuit

Daegu District Court-2015-Gu Partnership-22037 (2016.02.17)

Title

An appeal litigation without going through a prior trial procedure is illegal.

Summary

(As in the first instance judgment, an appeal seeking revocation of a disposition under tax-related Acts is filed after going through the procedures for a request for examination or adjudgment as provided by the Framework Act on National Taxes. Therefore, an appeal litigation without going through such procedures is illegal because it has not gone through the procedures for filing a request for examination or adjudgment, even if it has

Related statutes

Article 55 of the Framework Act on National Taxes

Article 56 of the Framework Act on National Taxes concerning other Acts

Cases

2017Nu6229 Revocation of revocation of imposition of transfer income tax

Plaintiff and appellant

Ma-○

Defendant, Appellant

○ Head of tax office

Judgment of the first instance court

Daegu District Court Decision 2015Guhap22037 Decided February 17, 2016

Conclusion of Pleadings

April 20, 2018

Imposition of Judgment

May 18, 2018

Text

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The judgment of the first instance shall be revoked. The imposition of capital gains tax on October 5, 2016 rendered by the Defendant to the Plaintiff on October 5, 2016 shall be revoked.

Reasons

1. Quotation of judgment of the first instance;

The reasoning of the judgment of the court on this case is the same as that of the judgment of the court of first instance, and thus, it is acceptable to accept this in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the

2. Conclusion

Therefore, the lawsuit of this case is dismissed as it is unlawful, and the judgment of the court of first instance is justified, and the plaintiff's appeal is dismissed. It is so decided as per Disposition.