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 court’s explanation as to this case is as stated in the reasoning of the judgment of the first instance, except for the following addition to the text of the judgment of the first instance. Thus, it shall be cited by Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

On the 5th page of the judgment of the court of first instance, the following additional contents are added to the 7th judgment of the court of first instance, and as long as the criminal judgment related to it has already become final and conclusive, it cannot be recognized that it is difficult to employ the fact judgment in the administrative litigation, unless there

(1) In order to determine whether or not a tax disposition is subject to a tax disposition, the following items should be added (see, e.g., Supreme Court Decision 2004Du2042, May 13, 2004). Article 7 of the first instance judgment (see, e.g., Supreme Court Decision 2004Du2042, May 13, 2004). Then, Article 7 of the first instance judgment provides that "if a tax disposition is to be deemed null and void a tax disposition, it is not sufficient to say that there is an unlawful ground, and its defect is objectively obvious, and it must be objectively obvious, and at the same time, it is necessary to consider the purpose, meaning, function, etc. of the laws and regulations on which the tax disposition is based, and to reasonably consider the specificity of the specific case itself. From this perspective, if there is any objective reason to believe that the tax disposition is subject to a tax disposition on any legal relation or factual relations that is not subject to a tax disposition, and if it can only be investigated whether it is subject to a tax disposition.