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1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
3. The judgment of the court of first instance No. 1 and No. 2
Reasons
1. The reasoning of the judgment of the court of first instance, such as accepting the judgment of the court of first instance, is as stated in the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as stated in the following (3). As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.
2. Subsequent to the amendment 3 pages 1, “the Defendant” added 4 pages 2, 15, 5 pages 1, 14, 17, 18, 19, and 20 “the revocation” to “a confirmation of invalidation”, respectively, and added “a confirmation of invalidation” to “a litigation of part 6, 5, 8, 5, and 2 below,” respectively, for the following four pages 6, 5 pages 6, and 7 below to “a confirmation of invalidation”, respectively, for the following 4 pages 6, 5 pages 4 to “a confirmation of invalidation”, and for the following 5, 5 pages 4 to “a confirmation of invalidation”, respectively.
3. Supplementary and additional Plaintiff asserts as follows.
① The Defendant, as a disposition on March 3, 2010, determined capital gains tax amounting to KRW 147,861,939, KRW 12,050,486, and additional tax amounting to KRW 34,163,129, as well as KRW 147,861,939, and KRW 147,861,939, and KRW 147,861,939, and KRW 12,050,486, and KRW 34,163,128, were corrected by the disposition on December 7, 2012.
The disposition as of December 11, 2012, which was issued as of December 7, 2012, became extinct, and only the disposition as of December 11, 2012, which was issued as of December 11, 2012, is a subject of dispute, and thus, the Plaintiff can contest the illegality of the principal tax and the additional tax as of December 11, 2012.
On the other hand, as recognized by the first instance judgment cited by this Court, the Supreme Court rendered a judgment that “the imposition of penalty tax on October 18, 2012 without stating only the sum of the penalty tax in the imposition of penalty tax and disclosing the type thereof and the basis for calculation of the tax amount” is unlawful.