1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning for the judgment of the court of first instance cited this case is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the judgment of the plaintiff as to the assertion that the plaintiff emphasizes again in the trial of the court of first instance as set forth in paragraph (2) above. Thus, this is acceptable as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main text

2. Additional determination

A. The Plaintiff’s assertion 1) The Defendants’ imposition of national taxes is contrary to the principle of taxation based on the presumption of taxation prescribed by the Inheritance Tax and Gift Tax Act, not based on the method of field investigation or the method of estimated assessment prescribed by the pertinent Act, by simply estimating the amount deposited within the limit of 377 meters from the place of business as the medical income amount. 2) The imposition of national taxes is contrary to the principle of taxation based on the global income tax belonging to the head of the North Incheon District Tax Office in 2012.

B. 1) As to the first argument, the burden of proving the fact of taxation requirements should be borne by the imposing authority in a lawsuit seeking the revocation of a tax imposition disposition. However, in a case where it is proved that the facts alleged to have been taxable requirements in light of the empirical rules in the course of a specific lawsuit are inappropriate to apply the rules of experience, or there are special circumstances to exclude the application of the rules of experience in the pertinent case, the pertinent taxation disposition cannot be readily concluded as an unlawful disposition that failed to meet the taxation requirements (see, e.g., Supreme Court Decisions 2002Du6392, Nov. 13, 2002; 2006Du6383, Sept. 22, 2006; 2006Du6383, supra. In addition to the circumstances in the instant case and the first instance trial, the following circumstances, which can be acknowledged by the overall purport of each entry and pleading in subparagraph 1-1, 2, and the amount of sexual surgery at the Plaintiff’s workplace, namely, the type and location of the Plaintiff’s workplace.