Seoul High Court-2017-Nu61791 ( November 24, 2017)

(In the case of fraud or other unlawful act, the exclusion period of 10 years shall apply.

(b)The ten-year exclusion period is applied because it is recognized that the active concealment intention to evade the tax was objectively revealed, or that there was a fraud or other unlawful act.

Article 26-2 of the Framework Act on National Taxes (Period for Excluding Assessment of National Taxes)

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the appellant's ground of appeal falls under Article 4 of the Act on Special Cases concerning the Trial Procedure, and it is therefore dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by the assent of all participating Justices.

April 12, 2018