Whether a tax notice for re-issuance is an administrative disposition

A tax notice for re-issuance is not a new disposition against the plaintiff, but merely a notification of global income tax and additional dues, which cannot be deemed an administrative disposition subject to appeal litigation.

Article 55 of the Framework Act on National Taxes

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance shall be revoked. The defendant's imposition of 40,181,670 won of global income tax for the year 1996 against the plaintiff on October 13, 2004, and 36,284,380 won of global income tax for the year 1997, and 10,884,180 won of global income tax for the year 1998 shall be revoked.

The court's explanation on the instant case is identical to the reasoning of the first instance court's judgment, and thus, citing it as it is in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil

Therefore, the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.