1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

The reasoning of the judgment of the court of first instance is to be stated in the reasoning of the judgment of the court of first instance, with regard to the new argument in this court, the court added the same judgment as that of paragraph (2) and, on the 3rd page, dismissed the contents of the 10 comprehensive proposal below as “the number of pages is included; hereinafter the same shall apply), and except for adding “the addition of the relevant Acts and subordinate statutes” to the corresponding parts of the attached Acts and subordinate statutes of 14 and 15, as stated in the reasoning of the judgment of the court of first instance, it shall be cited in accordance with Article 8(2)

The director of the Daejeon Regional Tax Office, having no reason to conduct a tax investigation against the plaintiff, appointed the plaintiff as the subject of tax investigation, and the scope of tax investigation was expanded from the transfer tax to the gift tax without giving any notice to the plaintiff, unlike prior notice by the director of the Daejeon Regional Tax Office to the effect that the plaintiff would conduct a tax investigation on the transfer income tax.

In addition, the plaintiff did not receive prior notice of tax investigation from the director of the Daejeon Regional Tax Office, and the notification of the result of tax investigation and tax investigation to the plaintiff is unlawful because it does not meet the requirements

In full view of the above, the tax investigation against the plaintiff is illegal, and the disposition of this case based on the result of the tax investigation is also illegal.

Judgment

Article 81-6 (4) of the Framework Act on National Taxes provides that "a tax official may conduct a tax investigation to determine the tax base and amount for the items of taxation for which tax base and amount of tax are determined through the investigation by a tax authority," and Article 81-9 (1) of the same Act provides that "tax official may conduct a tax investigation in order to determine the tax base and amount of tax for the items of taxation for which tax are determined through the investigation by the tax authority, except in cases prescribed by Presidential Decree, where it is confirmed that