All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1. The re-examination decision, which is conducted in practice as a type of a decision on a request for examination or a request for adjudgment, which is a procedure for objection to the disposition imposing tax, takes effect as a decision by supplementing its contents by a subsequent disposition following a reinvestigation. Therefore, it is reasonable to deem that the period for filing an administrative litigation is calculated from the date when the taxpayer who filed the request for examination or adjudgment

(See Supreme Court en banc Decision 2007Du12514 Decided June 25, 2010 (see Supreme Court en banc Decision 2007Du12514, Jun. 25, 2010). However, the re-assessment decision is ordinarily taking the form of re-auditing the matters pointed out in the pertinent decision regarding a specific disposition of imposing taxes and then re-auditing the tax base and tax amount or maintaining the initial disposition according to the results thereof, in principle, the disposition

However, in cases where the main place of business of a taxpayer differs from that of the place of tax payment or is related to a number of taxpayers who have different jurisdiction, the head of a tax office or the director of a regional tax office having jurisdiction over the place of tax payment, as well as the director of a regional tax office or the director of a regional tax office having jurisdiction over the place of tax payment, may conduct a tax investigation lawfully, and in such cases, it is not different from that of a reinvestigation according to the decision of a reinvestigation. Therefore, it is reasonable

In light of the existence of the authority to conduct re-audit, complementary nature of the authority to conduct re-audit and its impact on taxpayers, if the relevant administrative agency has lawfully conducted re-audit according to the re-audit decision and has specified that it is a notification of follow-up disposition in accordance with the re-audit decision.