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

The reasoning for the court’s explanation on the instant case is as stated in Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, since it is the same as the ground for the judgment of the court of first instance, except for the amended provisions under

2. Parts to be corrected;

3. The following are amended: 3. Whether the instant disposition is legitimate or not:

3. Whether the instant disposition is lawful

A. Summary of the plaintiff's assertion

Even if the Defendant did not serve a notice on the Plaintiff or served the notice on the Plaintiff’s side, the Defendant did not have the authority to receive the above notice, so the instant disposition is null and void.

B. Determination

The Framework Act on National Taxes (amended by Act No. 6782 of Dec. 18, 2002) provides that the documents under this Act or other tax-related Acts shall be served on the domicile, residence, place of business or office of the person in whose name the documents are to be served (Article 8(1)); the documents to be served by delivery or postal service (Article 10(1)); and the documents to be served by delivery shall be served on the person in whose name the documents are to be served at the place where the documents are to be served by the relevant administrative agency (Article 10(3)); Provided, That if the person to be served with the documents refuses to be served, they may be served at another place (Article 10(3)). Here, the term "person to be served with the documents" includes not only the person in whose name the documents are to be served but also the delegated person with the authority to receive them (see Supreme Court Decision

Based on this, in light of the following circumstances recognized by the health care unit, Gap evidence Nos. 12, 17, Eul evidence Nos. 4, 5, and 6 and the purport of the whole pleadings, the instant disposition is deemed to have been lawfully served. Thus, the plaintiff's assertion on this part is without merit.

1) The headCC performed the Plaintiff’s representative director from February 26, 1996 to July 24, 1998. The LB was appointed as the director on March 30, 1992 and was dismissed on February 7, 1996. In other words, he re-appointed to the director on February 26, 1996 and performed the director’s office until August 21, 200. Furthermore, the date of the above registration of dismissal and re-registration is the same.

2) From July 3, 1996 to March 18, 1998, the headCC and LBB, who were the representative director at the time, visited the tax office from time to time to time to verify matters necessary for the imposition of various corporate taxes, public auction, etc., or received a tax payment notice directly. Furthermore, since February 1996, LB was entirely responsible for receipt of the tax notice or the notice of public auction and related work after the public auction on the real estate owned by the Plaintiff, it was difficult to find out the necessary matters, each time the public auction on the real estate owned by the Plaintiff, and every time the public auction on the real estate owned by the Plaintiff.

3) Around June 15, 1998, the Defendant sent a notice of tax payment of the instant disposition to the Plaintiff, but returned, the Defendant issued a notice of tax payment directly to the tax office that can contact at the time, and the premiumB signed the Defendant’s delivery book.

4) On July 24, 1998, when the above headCC resigned from the representative director, KimD was appointed as the representative director. Since September 9, 2000 when the above headCC resigned from the representative director, HB maintained the Plaintiff’s director position until August 21, 200.

5) It does not seem that the above headCC or KimD raised an objection against the receipt of a tax notice or a public auction notice before and after the instant disposition and the processing of the relevant issues.

6) In full view of these circumstances, it is reasonable to deem that the Plaintiff’s director at the time of the instant disposition had the authority to receive the tax payment notice against the Plaintiff.

7) On June 27, 1998, the Plaintiff filed an application with the Plaintiff for a payment order claiming the payment of unpaid wages against the Plaintiff, and seized the Plaintiff’s real estate, etc. The reason for the tax office related to the public sale procedure was that the Plaintiff was an act to receive the payment order of the Plaintiff and that the Plaintiff did not have the authority to receive the payment order. However, it is insufficient to deem that the application for the payment order of the Plaintiff and the provisional seizure application of the Plaintiff did not interfere with the recognition of the above receipt right or that the B’s receipt right was extinguished at the time of the instant disposition.

3. Conclusion

Therefore, the judgment of the first instance is just, and the plaintiff's appeal is dismissed as it is without merit, and it is so decided as per Disposition.