Seoul High Court-2017-Nu-8574 ( August 24, 2018)

(Re-disposition in accordance with the purport of the judgment within the special exclusion period even before the judgment becomes final and conclusive, it shall be deemed within the exclusion period of national tax assessment.

(C) Article 26-2(1) of the former Framework Act on National Taxes does not apply to cases where a taxpayer is dissatisfied with the initial imposition disposition through an appeal procedure, such as an appeal procedure. In such cases, the period of exclusion under Article 26-2(1) of the former Framework Act on National Taxes shall not apply.

Article 26-2 of the former Framework Act on National Taxes (Period for Excluding Imposition of National Taxes)

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as per Disposition