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 is as stated in the reasoning of the judgment of the court of first instance except for the dismissal of some contents and addition of some contents as follows. As such, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act

Part that is dismissed or added shall be from 3 to 7 of the judgment of the court of first instance as follows.

A. The Plaintiff is the Plaintiff’s private teaching institute (hereinafter “instant private teaching institute”) on the Suwon-si B and the fifth floor in Suwon-si.

(2) The Defendant: (a) determined the tax base and the amount of tax on October 12, 2015, and imposed and notified KRW 5,623,449, the amount of tax unpaid on September 16, 2015 (hereinafter “instant disposition”).

A) Around October 16, 2015, the initial disposition of the instant case reached the Plaintiff. The following is added to the lower part of the third instance judgment No. 18 of the first instance court.

D. 1) The Plaintiff asserts that an administrative appeal required as a prior trial procedure of an administrative litigation is not in need of strict form in light of the fundamental purport of the appeal system to relieve a person whose rights and interests have been infringed due to an illegal or unfair administrative disposition. Therefore, the Plaintiff’s filing of a civil petition for grievance within the filing period should be deemed as an objection under the Framework Act on National Taxes

2) The former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same applies)

In any of the following cases, a person who has filed a tax base return by the statutory due date of return may request the head of the competent tax office to determine or correct the tax base and amount of the national tax for which the initial return or revised return has been filed within five years after the statutory due date of return expires:

Provided, That the disposition shall not be made with respect to the increased tax base and amount of tax due to the decision or revision.