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

This Court's explanation is identical to the corresponding part of the reasoning of the judgment of the court of first instance except for dismissal as follows. Thus, this Court's explanation is accepted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The "amount of income" of 11, 2, 2, 2 of the first instance court judgment, shall be regarded as "amount of income".

At the bottom of 2th judgment of the first instance court, "the plaintiff" is called "the plaintiff is listed with the tax agent and then through the tax agent."

○ The following shall be added between 3 pages 7 and 8 of the first instance judgment:

F. On June 30, 2014, the Plaintiff filed a final return on global income tax base for the year 2013, and the said return was prepared by the Plaintiff’s tax agent. At the time of the said final return, the Plaintiff also submitted a certificate of bona fide return stating that the said return has faithfully verified the income amount on the said return pursuant to Article 70-2(1) of the Income Tax Act. The “business income statement” of the said return means the total income amount of KRW 0 million,000,000,000, and the “detailed income statement” means the total income amount of KRW 00,000,000,000,000 + the total income amount of KRW 0,000,0000,000 + the total amount of KRW 0,000,000,0000,0000,0000,0000.

○ 3 pages 8 and 9 of the first instance court judgment [based on recognition] add “B No. 6” to the following:

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

① As the Defendant demanded the Plaintiff’s tax agent to file a revised return on the tax base, etc. for the first period of value-added tax in 2013, the employee of the said tax agent files the revised return of this case by mistake without the Plaintiff’s intent. The Plaintiff’s claim for correction was to correct it, but the disposition rejecting the claim

② The Plaintiff notified the Plaintiff of the omission of income amounting to KRW 00,000 from the first to the first period from the Plaintiff’s place of business in 2012, which was found in the field verification, and paid the value-added tax on the said omitted income. Accordingly, even though the instant revised return for the same taxable period was unnecessary, the instant disposition rejecting the request for correction was unlawful as it violates the principle of prohibition of double taxation.

B. Relevant statutes

It is as shown in the attached Form.

(c) Fact of recognition;

This Court's explanation is the same as the corresponding part of the reasoning of the judgment of the court of first instance (from 3 pages to 5 pages 4), except as follows. Thus, this Court's explanation is accepted in accordance with Article 8 (2) of the Administrative Litigation Act, Article 420 of the Civil Procedure Act, and Article 420 of the Civil Procedure Act.

○ From the bottom of 3 up to 2,30 up to the following:

1) On September 2013, the Plaintiff discovered a separate borrowed account related to the Plaintiff’s business establishment and notified the Plaintiff of the fact related to theCC tax secretary under the jurisdiction of the Plaintiff’s domicile. On November 14, 2013, the Plaintiff sent, through a tax agent, to the person in charge of the investigation of theCC tax secretary and on-site verification, a revised report guide received from the DD regional tax office by facsimile, and then asked the Plaintiff of the processing thereof, with the period subject to the revised report and the period of the borrowed account data overlap. The CC secretary respondeded that the field investigation on the processing of the borrowed account data is scheduled to proceed separately from the above revised report.

○ 2-3(c), (2), and (3) (from the bottom of 3 pages to the 1st eth eth 1st eth eth eth eth eth eth eth eth eth eth eth eth eth ), the term "

○ 5 pages 6 through 9 of the Act on the Protection, etc. of Specifics. shall be applied to 5 through 9 of the Act on the Protection, etc. of Specifics.

D. Determination

(1) Whether there exists a report of modification by the Plaintiff’s intent

Comprehensively taking account of the following circumstances revealed by the facts acknowledged earlier, the instant revised report cannot be deemed to have been filed without the Plaintiff’s intent. The Plaintiff’s assertion that differs from the premise is without merit.

① Around October 2013, the Plaintiff received a revised tax report from DD regional tax office, and submitted a revised tax return (in addition to KRW 00,000,000 to sales outside of a regular receipt among the tax base) to DD regional tax office on November 11, 2013 with respect to the value-added tax for the first period of November 201, 2013. The details of the revised tax return and the instant revised tax return are identical, and it was conducted before the on-site verification was conducted separately from the on-site verification procedure.

② The amount discovered in the instant field verification is merely 0,000,000 won (from 1, 2012 to 1, 2013) and thus falls considerably short of 00,000,000 won, which is the additional tax base for the first period of 2013 according to the draft return submitted to the regional tax office, which was submitted by the Plaintiff. The Plaintiff had been aware that at least 00,000,000 won had been omitted sales to the tax authority for the first period of 200,000,000 won, and the Plaintiff was 00,000,000,000 won for the instant field verification prior to the said field verification, and 00,000 won for the Plaintiff’s total revenue from 0,000 won for the instant field verification, and 00,000,000,000 won for the instant global income tax agent’s tax base verification method, and 00,000,0000,0000 won for the instant tax base return.

(ii) whether the additional addition of the revised declaration and the omission of the declaration discovered in the field verification overlap;

In full view of the following circumstances revealed by the facts as seen earlier, it is difficult to deem that the additional portion of the instant revised return overlaps with the revenue from the omission of the report discovered in the instant field verification. The Plaintiff’s assertion is without merit.

① On-site verification is conducted within a limited purpose and scope, unlike a tax investigation, as a single verification for the handling of tax evasion reporting materials, taxation data, etc., and the instant on-site verification was conducted by the Plaintiff only by analyzing the details of deposits in the Plaintiff’s borrowed account, based on the tax evasion report that the Plaintiff omitted the receipt of the relevant revenue by way of the borrowed account by marriage. As such, the entire amount of revenue omitted in the pertinent taxable period is not discovered.

② On-site verification in the instant case reveals the omitted income amount from the first to the first half of 2012, and the revised return in the instant case pertains to the omitted portion in the first half of 2013 and the taxation period partially overlap. However, if a taxpayer asserts that the tax base and tax amount reported by him/her were wrong, it is in accord with the empirical rule and equity to deem that it is necessary for the taxpayer to prove that it is easy for him/her to present all data, such as keeping books and documentary evidence.

③ The revised return of this case was made in accordance with the guidance of the regional tax office to submit explanatory materials or a revised return because suspicions that the Plaintiff had omitted a report on the amount of revenue, or omitted a report on the amount of revenue, such as Switzerland, dricks, and dracks, which are included in the wedding business, by inducing consumers to settle cash, while providing discount benefits. As such, the revised return of this case and on-site confirmation of this case are different from the circumstances, and from the scope of revenue omitted.

3. Conclusion

The judgment of the first instance is justifiable. The plaintiff's appeal is dismissed.

Relevant statutes

Framework Act on National Taxes (Amended by Act No. 12848, Dec. 23, 2014)

Article 45 (Revised Return)

(1) In any of the following cases, a person who has filed a tax base return by the statutory due date of return (including a person falling under any of Article 73 (1) 1 through 7 of the Income Tax Act) may file a revised tax base return before the head of the competent tax office determines or corrects and notifies the tax base and amount of the relevant national tax under the tax-related Acts, and the period under Article 26-2 (

1. Where the tax base and tax amount entered in the return of tax base is short of those to be reported under tax-related Acts;

2. The deficit amount or refundable tax recorded in the tax base return or the amount of deductible expenses to be reported under tax-related Acts.

(b) If the tax amount exceeds

3. Where incomplete returns are made due to grounds prescribed by Presidential Decree, such as an ommission in the course of exact calculation, tax adjustment, etc. by a withholding agent, other than subparagraphs 1 and 2 (excluding where a request for correction, etc. under Article 45-2 may be filed).

Article 45-2 (Request for Correction, etc.)

(1) In any of the following cases, a person who has filed a return on a tax base by the statutory due date of return may request the head of the competent tax office within three years after the statutory due date of return elapses to determine or correct the tax base and amount of the national tax for which the initial return and revised return have been filed: Provided, That with respect to the increased tax base and amount of tax due to a determination or correction, a request for correction may be made within 90 days (limited to within three years after the statutory due date of return expires) from the date he/

1. Where the tax base and amount of tax on a return of tax base (referring to the tax base and amount of tax after determination or correction is made, if such determination or correction is made pursuant to the tax-related Acts), exceed those to be reported under the tax-related Acts

2. Where the deficit amount or refundable tax amount entered in the return of tax base (referred to the deficit amount or refundable tax amount after such decision or correction is made, if such decision or correction is made pursuant to the tax-related Acts), is short of the deficit amount or refundable tax amount to be declared under the tax-