The instant lawsuit is dismissed.

Litigation costs shall be borne by the plaintiff.

1. The final tax return for which the final tax return for global income tax was not filed on November 30, 2009, on the grounds of taxation in arrears of the tax base due date for payment on December 17, 2010, with the global income tax of KRW 1,988,290 and KRW 585,240 on November 30, 2009, for which the final tax return for global income tax of KRW 585,240 on November 30, 2009 was not filed on September 21, 201, with the global income tax of KRW 1,983,540 on December 17, 2010, for which the final tax return for global income tax of KRW 876,390 on December 17, 201, for which the final tax return for global income tax of KRW 876,368,490 on December 31, 201, for which the tax return for final tax return reverts in 2080,80.

A. At the time of May 7, 2019, the Plaintiff was delinquent in the comprehensive income tax as follows.

B. On May 7, 2019, the Plaintiff filed an application with the Defendant for special exception to the extinguishment of the obligation to pay delinquent amount in arrears pursuant to Article 99-5 of the Restriction of Special Taxation Act and Article 99-5 of the Enforcement Decree of the same Act. However, on July 2, 2019, the Defendant notified the Plaintiff that the obligation to pay delinquent amount is not extinguished (hereinafter “instant disposition”).

[Ground of recognition] Facts without dispute, Gap evidence 4, Eul evidence 1, the purport of the whole pleadings

2. Determination on this safety defense

A. As to the assertion that the disposition of this case is unlawful, the purport of this defense is that the Plaintiff’s present amount in arrears is less than KRW 30 million, and that it was illegal for the Defendant to regard the Plaintiff as the business income subject to withholding tax, which is not the employee, even though the Plaintiff worked as an agent from January 1, 2018 to December 31, 2017, even though he/she had been employed as an agent, the Defendant asserted that the lawsuit of this case is unlawful since it was filed without going through a prior trial procedure such as a request for review or a request for trial under the Framework Act on National Taxes.

B. The main text of Article 56(2) of the Framework Act on National Taxes provides, “The administrative litigation against a disposition under the Framework Act on National Taxes or the tax-related Acts shall not be instituted without going through a request for examination or adjudgment under this Act and a decision thereon, notwithstanding Article 18(1), (2) and (3) of the Administrative Litigation Act.”