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.

1. The reasoning of the judgment of the court of first instance citing the instant case is added or used as follows, and the judgment on the Plaintiff’s assertion that was newly raised in this court is added to the judgment of the court of first instance as stated in the reasoning of the judgment, and thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Supplementary or height parts] Of the three pages of the upper part, "207-2010" of the extension of the scope to the plaintiff shall be "2007".

The 5th 6th 6th eth eth 1 to 21th eth eth eth eth eth eth eth e.

From 6 pages 3 to 7, 21, the following shall apply:

Article 81-4(1) of the former Framework Act on National Taxes (amended by Act No. 9911, Jan. 1, 2010; hereinafter “former Framework Act on National Taxes”) provides that “tax officials shall conduct a tax investigation to the minimum extent necessary to realize proper and fair taxation and shall not abuse their right of investigation for any other purpose.” Furthermore, Article 81-4(2) of the former Framework Act on National Taxes (hereinafter “instant legal provision”) provides that “tax officials shall not conduct a re-investigation on the same item of tax and the same taxable period unless they fall under any of the following subparagraphs, unless there is any clear material to acknowledge the suspicion of tax evasion” (Article 1), “where it is necessary to conduct an investigation on the other party to a transaction” (Article 81-4(1) of the former Framework Act on National Taxes), and “where there is any error in relation to two or more business years” (Article 3).

(2) The relevant legal doctrine (A) Tax investigation is likely to seriously undermine the taxpayer’s freedom of business or legal stability and lead to the abuse of the right to conduct tax investigation. Therefore, Article 81-4(1) of the former Framework Act on National Taxes is subject to tax investigation.