The costs of appeal are assessed against the plaintiff.

1. As to ground of appeal No. 1

A notice of tax payment as a disposition on a person jointly and severally liable for tax payment should be issued individually to each person jointly and severally liable for tax payment. However, in a case where a notice of tax payment as a disposition on a person jointly and severally liable for tax payment is individually made to each person individually, the lawfulness and validity of such notice of tax payment should be determined individually solely on the relevant tax payment notice. Unless another person jointly and severally liable for tax payment individually and severally liable for tax payment, it cannot be deemed that such notice is unlawful as a matter of course on the ground that it cannot be served on or constitutes a notice of tax payment on

According to the reasoning of the judgment below, the court below acknowledged that the real estate of this case is jointly owned by the plaintiff et al. and six other persons, and that the defendant served a notice of tax payment stating "non-party six other persons" as a joint and several taxpayers other than the plaintiff in the payment of registration tax and acquisition tax as a taxation disposition. The above notice of tax payment is not a tax payment notice but a tax payment notice on the remaining six persons except the plaintiff, and it does not have a separate tax payment notice. Thus, the judgment of the court below is just in accordance with the above legal principles and it does not err by misapprehending the legal principles as to the tax payment notice on the joint and several taxpayers.

The Supreme Court Decision 85Nu81 Decided October 22, 1985 cited by the theory of the lawsuit is that even if a person jointly and severally liable for tax payment is a person jointly and severally liable for tax payment, the specific tax liability for each person individually established and determined is required to be determined, and thus, to impose specific tax liability on each person jointly and severally liable for tax payment, only the representative or a person who is convenient for collection cannot be notified to each person jointly and severally liable for tax payment with the name of the title holder. As such, even if another person jointly and severally liable for tax payment receives a tax payment notice as a disposition of imposition, it cannot be deemed that a disposition of imposition was taken against a person jointly and severally liable for tax payment who fails to receive the tax payment notice, and it cannot

2. Regarding ground of appeal No. 2

According to the provisions of Articles 120, 130(2), and 90 of the Enforcement Decree of the Local Tax Act, the acquisition tax and registration tax, which are local taxes, shall be paid by a taxpayer by voluntary return to the tax base amount and the tax amount. According to the provisions of Articles 121(1) and 151 of the same Act, in a case where a taxpayer of acquisition tax and registration tax fails to make voluntary return and payment, or the paid tax amount falls short of the tax amount under the provisions of the Act, the tax authorities shall collect by the ordinary collection method the tax amount calculated or underpaid tax plus 20/100 of the tax amount. As determined by the court below, if the Plaintiff reported and paid tax amount below the tax amount under the provisions of the Act in advance due to voluntary return and payment of the registration tax and acquisition tax, the amount calculated by adding 20/100 to the shortage of tax amount under the provisions of the above Act, and thus, the Defendant’s disposition of this case, which issued the tax payment notice along with the shortage of tax and additional dues, is justified.

3. Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.

Justices Yellow-ray (Presiding Justice)