이 사건 처분 중 일부는 피고가 세무조사를 실시하기 전의 처분으로서 그 하자가 명백하다고 할 수 없어 무효로 볼 수 없음[일부국패]
Daejeon High Court (Cheongju)-2018-Nu1375 ( October 24, 2019)
Some of the dispositions in this case cannot be deemed null and void as it was a disposition before the defendant conducted a tax investigation, and its defect cannot be deemed evident.
(Summary) The disposition of this case rendered on June 1, 2010; February 8, 2011; May 2, 2011; and April 1, 2012, by the date of notification, cannot be deemed null and void as it was a disposition before the Defendant conducts a tax investigation.
Article 14 of the Framework Act on National Taxes
The records of this case and the judgment below and the grounds of appeal were examined, but the appellant's grounds of appeal are examined.
Since the assertion on the procedure of a trial is clearly justified because it falls under Article 4 of the Act on Special Cases Concerning Procedure for Trial, etc.
All appeals are dismissed in accordance with Article 5 of the same Act. It is so decided as per Disposition by the assent of all participating Justices.
this decision is delivered with the assent of all Justices.