The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Article 3(2) of the former Framework Act on National Taxes (amended by Act No. 12162, Jan. 1, 2014; hereinafter the same) provides for a special provision on national taxes imposed and collected by the head of the relevant customs office under the Customs Act, with regard to the assertion in the grounds of appeal concerning the period for claiming correction of liquor tax, the special provision on this Act shall apply.

In addition, Article 4(1) of the former Customs Act (amended by Act No. 11121, Dec. 31, 201; hereinafter the same) provides that “If the provisions of the Framework Act on National Taxes, the Liquor Tax Act, etc. and the Customs Act conflict with those of the former Customs Act concerning imposition, collection, refund, etc. of liquor tax imposed and collected by the head of a customs office on imported goods, the former Customs Act

Meanwhile, Article 23(3) of the former Liquor Tax Act (amended by Act No. 11134, Dec. 31, 201; hereinafter the same) provides that a person who imports alcoholic beverages shall submit a declaration under the Customs Act to the head of the competent customs office at the time of filing an import declaration. The former part of Article 38-3(2) of the former Customs Act provides that “When a person liable for duty payment becomes aware of an excessive amount of duty returned and paid (limited to cases where the period for correction expires), he/she may request the head of the competent customs office to rectify the amount of duty declared, as prescribed by Presidential Decree, within two years from

Article 45-2 of the former Framework Act on National Taxes provides for special cases concerning taxes imposed and collected by the head of a customs office, along with the content and structure of the provision, since the purpose of the special cases concerning taxes imposed and collected by the head of a customs office is to promote the efficiency of taxation administration and the equality among taxpayers by imposing and collecting taxes on imported goods along with customs duties, the appeal procedures therefor also need to be made the same as customs duties.