1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasons why the court should explain this case in this case are the 4th judgment of the court of first instance.

The part “as to the existence of interest in confirmation” as stated in the reasoning of the judgment of the court of first instance is identical to that of the judgment of the court of first instance, except in the following paragraph (2). Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of

2. As to the existence of interest in confirmation

A. In general, an obligee under the civil law may apply for compulsory execution against an obligor’s property in accordance with a final and conclusive judgment after having received a final and conclusive judgment for the purpose of compulsory realization of a claim. However, the obligee may directly determine the specific contents of the pertinent tax claim and have self-reliance right to seize and liquidate the property of a delinquent taxpayer. Therefore, the benefit of a lawsuit that can determine a tax claim through a separate judicial claim cannot be recognized as a general prior area. Article 27 of the Framework Act on National Taxes provides for the extinctive prescription of the right to collect national taxes. Article 28(1) of the Framework Act on National Taxes provides for the interruption of the extinctive prescription, and Article 28(1) provides for “tax payment notice, demand notice or demand for payment, demand for delivery, demand for delivery, and seizure.” As such, in principle, as the Framework Act on National Taxes provides for the interruption of the extinctive prescription of a tax claim by means of “payment demand for payment, demand for payment demand for delivery, demand for delivery, and seizure” under the collection procedure, it is difficult to view that a judicial claim is generally permissible.