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 reasons why the court should explain in this part of the reasons for the decision of the court of first instance are the same as the corresponding part of the reasons for the decision of the court of first instance (from the 6th to the 3th day below the second one). Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Determination on this safety defense

A. On April 4, 2013, after the deadline for filing a request for a trial was over, the Plaintiff filed a request for a trial with the Tax Tribunal to dismiss the request, and thus, the Plaintiff did not undergo the necessary procedure for a prior trial.

Therefore, the instant lawsuit is unlawful.

B. Determination 1) The former Framework Act on National Taxes (amended by Act No. 8139, Dec. 30, 2006; hereinafter the same applies)

According to Article 56(2) of the Act, an administrative litigation against a disposition under tax-related Acts may not be filed without going through a request for evaluation or adjudgment under the Framework Act on National Taxes and a decision thereon. In this case, a request for evaluation or adjudgment shall be lawful, such as having to comply with the request period. In a case where a request for evaluation or adjudgment is illegal due to the passage of the time period, administrative litigation shall also be deemed unlawful because it does not meet the requirements for transfer (see Supreme Court Decision 90Nu8091, Jun. 25, 1991). Meanwhile, pursuant to Articles 61(1) and 68(1) of the former Framework Act on National Taxes, a request for evaluation or adjudgment shall be filed within 90 days from the date on which he/she becomes aware that the relevant disposition was

In addition, if special mail such as ordinary mail or registered mail is delivered in an apartment where the taxpayer resides, apartment security guards have received and delivered it to the resident, and if apartment residents such as the taxpayer have not raised any objection with respect to the delivery method of ordinary special mail, the resident of the apartment where the taxpayer resides can have the right to receive the registered mail.