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 of the judgment of the court of first instance for the acceptance of the judgment is as follows: (a) the reasoning of the judgment of the court of first instance is as follows, except for the parts to be determined additionally in the following paragraphs; and (b) thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of

11. The term "Korea" of the 7th parallel of conduct shall be changed to "Korea".

12. The following shall be added to the "a fixed point" of six pages:

【The Plaintiff not only contributed not only to profit-making activities in Korea but also to non-profit activities in Korea, i.e., the amount of KRW 61 million in 2006, KRW 41 million in 2007, KRW 66050,000 in 2008, and KRW 30 million in 2009)

2. Additional determination

A. Article 2(3)2 of the former Enforcement Decree of the Income Tax Act (hereinafter “Enforcement Decree of this case”) requires the principle of no taxation without law.

Since the disposition of this case is null and void in violation of the principle of clarity, it asserts that the disposition of this case based on this is unlawful.

B. The principle of no taxation without representation adopted by Articles 38 and 59 of the Constitution

The requirements and procedures for the exercise of tax rights, such as cases and collection procedures, must be prescribed by the law enacted by the National Assembly, the representative agency of the people; however, the summary of taxation;

It is not possible to delegate the matters concerning the cases and collection procedures to the subordinate laws and regulations such as the order rules, but it is not possible to stipulate them, and in the case of delegation to the subordinate laws and regulations, only a specific individual delegation is allowed, and the provisions of the order rules according to such laws and regulations should be meaningful and clear.

Therefore, taxation need

Whether it is against the principle of clarity or not, from the taxpayer’s standpoint, any act is taxable.

Whether it can be predicted that the term is subject to taxation as it falls under the relevant term, and the uncertainty of the relevant term is arbitrary and discriminatory from the position of the administrative agency.