The re-audit decision shall take effect as a decision on objection, etc. by supplementing the contents thereof by the follow-up disposition of the agency.

It cannot be said that there is no violation of the principle of non-defluence in subsequent disposition maintaining the contents of the original disposition, which deviates from the scope of the re-investigation decision or violates the principle of prohibition of disadvantageous change.

Article 79 of the Framework Act on National Taxes, Prohibition of Unfair Objections and Disadvantages, and Scope of deductible expenses under Article 19 of the former Corporate Tax Act

2014Guhap20412 Revocation of Disposition of Imposing corporate tax, etc.

AAA, Inc.

00. Head of tax office

November 4, 2014

December 12, 2014

1. All of the plaintiff's claims are dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Cheong-gu Office

(1) The Defendant imposes a disposition on the Plaintiff on December 3, 2012 on the imposition of KRW OO(OO207, KRW 2008, KRW O209, KRW O2009, KRW O2010, KRW 2011) of the Corporate Tax Act, ② the imposition of corporate tax for the year 2007 as of March 19, 2013, ③ the notice of the change in the amount of income for the year 2007, KRW 2010, KRW 2010, KRW 208,O208, KRW 200, KRW 201, O208, KRW 209, KRW 200, KRW 201, O208, KRW 200, KRW 201, O208, KRW 200, KRW 200, KRW209, respectively.

1. Details of the disposition;

(a) The relationship between the parties;

1) The Plaintiff was established on January 1, 1996 and OO also is a corporation of OOOB, which is engaged in the production and installation of automated lines and the business of manufacturing electrical and electronic parts, and OB is the representative director of the Plaintiff.

2) At present, the MediationCC is a member of the OO, who served as the chairperson of the party members council at the time of OO per O per O in 2007.

(b) Details of preparation and transfer of a loan certificate;

1) On April 19, 2007, the MediationCC prepared a loan certificate with a maturity of payment as of May 15, 2007 from OOOB to ParkB without interest. The above OOOO was withdrawn from the Plaintiff’s account on April 20, 2007, and the Plaintiff was deposited into the bank account in the name of the MediationCC through a substitute transaction.

2) On April 30, 2007, the MediationCC prepared a loan certificate with a maturity of payment as of May 5, 2007 from OOOB to GabB without interest. On April 30, 2007, the OOOB was withdrawn from the Plaintiff’s account on April 30, 2007, and then deposited ParkB into the bank account in the name of CC through a substitute transaction.

3) On May 17, 2007, the MediationCC prepared a loan certificate with the name of the recipient of the loan certificate without stating the name of the recipient, and on May 29, 2007, the OOOOOO was borrowed with the due date set as of May 29, 2007. On May 18, 2007, the above OOOO was withdrawn from the Plaintiff’s account under the Plaintiff’s name, and then was deposited into the bank account in the name of the MediationCC through a substitute transaction.

4) Meanwhile, the Plaintiff’s bank account was deposited in the Plaintiff’s name in total in the name of EE and GangwonF on May 4, 2007 and May 7, 2007.

5) The Plaintiff finally spent the above OOO as an advance payment on the financial statements for the business year 2007.

C. Progress of the relevant lawsuit

1) On January 12, 2010, ParkB filed a criminal complaint with 00 branch offices of 00 branch offices of 20th public prosecutor’s office of 00 branch offices of 20th public prosecutor’s office of 20th public prosecutor’s office against the above

"2) The reasons for the complaint are as follows. To acquire logistics business rights ordered by the GG industry corporation (hereinafter referred to as "GG industry") located in PGG industry as the representative director of the plaintiff's representative director, ParkB had been met at the time of the complaint by the OO of the PG industry, the representative director of PG industry, and the PGH had been in charge of the chairperson of the PG industry council at the time of the OO of the PG industry, and he was asked from PCC that money needs to be needed to proceed with the business of importing Dmond in China. However, the PCC had no intent or ability to pay the above money at the time of borrowing the above money. However, the PCC was also subject to a disposition to dismiss the above fraud by the PCC on February 3, 2012, but it was also suspected that there was no suspicion of the above fraud.

4) Meanwhile, ParkB filed a lawsuit against ChoCC seeking payment of loans 00 district court 002 002 01 Gohap 201 Gohap0000, and was sentenced to a favorable judgment on December 16, 2011. In addition, ParkB filed a lawsuit against ChoCC and PuD seeking payment of loans OB 000 as 00 district court 00 00 00 Gahap 010000, and was sentenced to a favorable judgment on April 27, 2012. Each of the above judgments became final and conclusive.

5) Based on the above 00 district court’s 00 branch court’s 00 branch court’s 201Gahap00000, ParkB intended to execute a collection order with respect to the benefit of 00 district court’s 00 branch court’s 00 branch court’s 00 01 Gahap0000, but it was impossible to enforce compulsory execution on the ground of the existence of senior claim.

6) The Plaintiff, among the OOO members appropriated as advance payments for the OO factory business license on the financial statements of the business year 2007, included the above OOO members in the raw materials cost during the settlement of accounts in the business year 2011.

(d) Process of tax investigation;

1) From September 17, 2012 to October 16, 2012, the Defendant conducted a tax investigation on corporate tax against the Plaintiff from September 17, 2012 to the business year from October 2011.

2) As a result of the tax investigation, the Defendant paid OOOO won to ChoCC, a political person that can exercise influence for acquiring the logistics business right ordered by the GG industry, and appropriated it as an advance payment. However, the possibility of recovery was deemed to have been lost as raw material cost in the name of bad debt, and determined that it was not a business deductible expense.

3) In addition, the Defendant assessed the remainder of the OOO as an asset irrelevant to business, which is appropriated in the foregoing advance, and determined that it was not deductible expenses for business operation of the OOO (OOO in 2007, 2008, OOOOOO in 2009, OOOOO in 2009, OOOOO in 2010, and OOOO in 2011) paid in relation to assets irrelevant to business.

4) In addition, from the business year 2009 to the business year 201, the Defendant included OOO in deductible expenses, and made tax adjustment, such as inclusion in deductible expenses of OOOO in gross income for the end inventory of the business year 2011.

E. Disposition of imposing corporate tax on December 3, 2012

1) Accordingly, on December 3, 2012, the Defendant issued a correction and notification (including additional taxes; hereinafter the same shall apply) of corporate tax to the Plaintiff on December 3, 2012, the Defendant disposed of the said OOOOO as other income for the 2007 OOCC, 2008, OOOO(209, 2009, OOOO(201), 2010, OOOO(201), and 2011. In addition, the Defendant disposed of the said OOO that was excluded from deductible expenses as other income for the OCC.

2) On January 4, 2013, the Plaintiff filed an objection with the commissioner of regional tax office, who was paid to the MediationCC, to the effect that all the interest paid to the above OOO members and the remainder OO members should be included in the deductible expenses, because it constitutes a loan that cannot be recovered to a person other than a specially related person.

(f) a decision of re-audit on January 25, 2013;

1) On January 25, 2013, the Director of the Regional Tax Office rendered a decision to re-examine whether the Plaintiff’s filing of the above objection constitutes losses for the business year 201, and whether KRW 500,000,000, appropriated as advance payment from the business year 2007 to the business year 2011, constitutes non-deductible assets subject to non-deductible interest, etc., and to order the correction of the corporate tax base and tax amount.

2) Accordingly, the Defendant conducted a reinvestigation on the Plaintiff from January 29, 2013 to February 12, 2012. As a result of the reinvestigation, the Defendant rendered a decision to maintain the disposition imposing corporate tax on December 3, 2012, supra, on the ground that it is reasonable to include the interest paid in advance as raw materials in non-deductibles as non-deductibles, and that it constitutes non-deductibles subject to non-deductibles. The Defendant notified the Plaintiff on June 12, 2013.

(g) Imposition of additional corporate tax and notice of changes in income amount;

1) In the process of the above re-investigation, the Defendant: (a) changed OOOB as a bonus disposition for 2007 for OOB, which was disposed of as other income in relation to OB, as a provisional payment for the representative director who was paid to OOB; (b) added it as separate taxation data; and (c) added OO directors paid in 2007 for 2007 for OOO directors; (d) added OO directors to gross income; (e) notified OO directors of 2007 for 2007 for OO directors; and (e) notified the Plaintiff of the change in the amount of income for 207 years and equivalent to 2007 for the OO directors.

2) In addition, on April 1, 2013, the Defendant notified the Plaintiff of the change in the income amount of the OOO members attributed to the year 2011, equivalent to the amount disposed of as bonus from the said representative director.

3) In other words, the Defendant included the interest paid for the above OO won for each business year (OO won for the year 2008, OO won for the year 2009, OOO won for the year 2010, OO won for the year 2011) in deductible expenses, and recognized the interest accrued for each business year for such OO won (OO won for the year 2008, OO won for the year 2009, OOO won for the year 2010, OO for the year 2011, for the corporate tax on August 1, 2013 (OO won for the year 208, for the year 2009, for the year 2010, for the above O200, for the business year O200, for each business year O200, for the above O209, for the 2010, O2000, O200.

(h) Procedures, etc. for the previous trial;

1) Meanwhile, among the disposition imposing corporate tax as of December 3, 2012, the part of the disposition imposing corporate tax on the Plaintiff and the details of the disposition imposing corporate tax and the notice of change in income amount as seen earlier are as follows (hereinafter collectively referred to as "the disposition in this case"). Among them, "the disposition in this case" is referred to as "the disposition in this case" and "the additional disposition in this case" is referred to as "the disposition in this case, including the disposition as of December 3, 2012, following the decision of reinvestigation as of January 25, 2013, excluding the disposition as of December 3, 2012, following the decision of reinvestigation as of March 19, 2013, April 1, 2013 and August 1, 2013

first day; and

Section 20

2007

208

209

2010

2011

December 3, 2012

Corporate Tax

OOOE

OOOE

OOOE

OOOE

OOOE

March 19, 2013

Corporate Tax

OOOE

March 19, 2013

Notice of Change in Income Amount

OOOE

April 1, 2013

Notice of Change in Income Amount

OOOE

August 1, 2013

Corporate Tax

OOOE

OOOE

OOOE

OOOE

August 1, 2013

Notice of Change in Income Amount

OOOE

OOOE

OOOE

OOOE

2) The Plaintiff filed another objection on May 21, 2013, but the objection was dismissed on June 28, 2013. The Plaintiff filed a tax appeal seeking the revocation of the instant disposition with the Tax Tribunal on September 3, 2013, but the appeal was dismissed on January 20, 2014.

[Reasons for Recognition] A without dispute, Gap evidence Nos. 1 through 6 (including each number, if any; hereinafter the same shall apply), Gap evidence Nos. 8 through 14, Gap evidence No. 16 through 22, Gap evidence No. 34, 35, Eul evidence Nos. 1, 2, 4, 5, 6, Eul evidence No. 7-1, 2, Eul evidence No. 7-2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

The instant disposition is unlawful for the following reasons.

1) On January 25, 2013, the Defendant changed the nature of the OOOO which was paid to Mediation Committee beyond the scope of the re-audit decision, from the bribe expenses to the provisional payment related to gambling B. After maintaining the disposition of imposing corporate tax on December 3, 2012, the instant additional disposition was rendered. Accordingly, the instant additional disposition deviates from the scope of the re-audit decision under the Non-U.S. Non-U. Non-U.S. Non-U. Non-U.S. Non-U. Non-U.S. Principle, thereby violating the principle of prohibition of disadvantageous alteration.

2) The OOOO personnel paid to the MediationCC was leased to the Plaintiff for the purpose of business assistance from the MediationCC to acquire the logistics business right of the GG industry, and the Plaintiff incurred losses of the OOO personnel because it was not repaid, which constitutes the requirement for inclusion of bad debts in deductible expenses. However, the Defendant rendered the instant disposition on the premise that ParkB received a provisional payment from the Plaintiff and lent it to the Mediation Committee.

3) Even if the above OOB withdrawn from the Plaintiff’s representative director and lent it to the ChoCC as seen in the instant disposition, its business relevance is sufficiently recognized. Thus, it cannot be deemed as a provisional payment in relation to the business subject to non-deductible. However, the Defendant rendered the instant disposition on the premise that it constitutes a provisional payment in relation to the business.

4) As above, the Plaintiff suffered losses from the OOO members, which is a transaction that reduces the Plaintiff’s net assets, but the Defendant denied the inclusion of the OO members in deductible expenses while rendering the instant disposition, violates the corporate tax taxation principle, the ability burden principle, and the substance over form principle, as a taxation on false income with no income subject to taxation.

5) The Defendant followed the instant additional disposition by the resolution of the advisory committee for determination of the taxation facts that had gone through the Plaintiff’s statement at the time of the initial disposition. The instant additional disposition was followed by the original public opinion expression, and thus violated the principle of trust and good faith.

6) In making the instant disposition, the Defendant deprived the Plaintiff of the opportunity to request a pre-assessment review on the instant additional disposition by failing to give notice of pre-assessment, even though the reason and content of the disposition were changed.

B. Relevant statutes

It is as shown in the attached Form.

C. Determination

1) Determination on the assertion such as violation of the principle of prohibition of disadvantageous alteration

A) Article 79(1) of the Framework Act on National Taxes provides that “The Council of Tax Judges or the Joint Session of Tax Judges shall not cancel or modify all or part of the disposition other than the disposition for which a request for adjudgment has been made, or make a decision on a new disposition.” In addition, Article 79(2) provides that “The Council of Tax Judges or the Joint Session of Tax Judges shall not make any decision unfavorable to the claimant than the disposition for which a request for adjudgment has been made.” In addition, the principle of prohibition of disadvantageous change is applied to the case of an objection without express provision.” However, it is generally applied to the case where the main contents of the decision on objection are more unfavorable to the claimant than the taxation subject to the objection, and it is not applicable to the case where the tax authorities make a decision on the tax base or tax amount omitted or erroneous on the basis of the details revealed by the grounds for which a request for adjudgment has been made (see, e.g., Supreme Court Decision 200

B) On the other hand, a re-examination decision which is conducted in practice as a type of the decision on the objection filing, etc. takes the form of re-auditing the matters pointed out in the relevant decision on the whole or part of a single taxable unit and correcting the tax base and tax amount or maintaining the initial disposition according to the result. Accordingly, only after receiving the notice of the subsequent disposition following the re-audit decision, the applicant, etc. who received the notice of the re-audit decision can specify the subject and scope of objection in the next stage litigation procedure. Considering the form and purport of the re-audit decision, and the unique nature of tax law that has autonomous administrative control and complicated and professional and technical nature of the administrative appeals system, the re-audit decision is bound to be deemed to have become effective as a modified decision in which the agency intended to take part of the subsequent disposition as part of the decision on the objection filing, etc. by supplementing the contents of the subsequent disposition by the disposition (see, e.g., Supreme Court en banc Decision 2010Du15475, Jun. 25, 2010).

C) Comprehensively considering these legal principles, we examine the above facts of recognition.

As a result of re-audit conducted against the Plaintiff from January 29, 2013 to February 12, 2012 by the Director of the Regional Tax Office’s decision of re-audit on January 25, 2013, the Defendant rendered a decision on February 21, 2013 to maintain the disposition imposing corporate tax as of December 3, 2012 to the Plaintiff as of December 3, 2012, and such decision constitutes the subsequent disposition immediately following the re-audit decision.

Although the nature of the OOOE paid to ChoCC in the course of a reinvestigation decision and the subsequent subsequent disposition may be deemed to have changed from the bribe to the provisional payment unrelated to gamblingB. However, since the objective existence of the tax amount determined by the tax authority, the subject matter of the lawsuit for revocation of a tax disposition is not always that the tax authority can determine the legality of the disposition by only the data at the time of the disposition or that only the reasons for the disposition at the time of the disposition can be asserted (see, e.g., Supreme Court Decision 20Du1994, Oct. 11, 202). In light of the fact that the purport of the re-examination decision by the commissioner of the regional tax office is to determine whether the OOOE paid to ChoCC constitutes a loan or who is the lessee, it cannot be said that the subsequent disposition maintained the contents of the original disposition was beyond the scope of the re-audit decision, or that there was an error in violation of the principle of prohibition of disadvantageous alteration.

D) Meanwhile, as seen earlier, the follow-up disposition following the reinvestigation decision shall be deemed to be the decision that the Defendant maintains the original disposition on February 21, 2013 as it is, and the instant additional disposition shall not be deemed as the subsequent disposition, as alleged by the Plaintiff.

The instant additional disposition is limited to the decision of correction of the tax base or tax amount erroneous based on the details revealed in the grounds of the above decision on objection. In addition to the fact that Article 72(2) of the Framework Act on National Taxes specifies the subject of the principle of prohibition of disadvantageous alteration as the Council of Tax Judges or the Joint Session of Tax Judges, which is the subject of the decision, the subject of the decision, and the special nature of the tax law relationship with autonomous administrative control and complicated, professional and technical nature of the administrative appeal system, the instant additional disposition issued by the

Therefore, this part of the plaintiff's assertion is without merit.

2) Determination as to the assertion regarding the bad debt requirement

In full view of the following circumstances revealed by the above facts, it is reasonable to view ParkB’s withdrawal of the Plaintiff’s deposit and lending of OOB to the Mediation Committee, and it is insufficient to reverse this only with the testimony of Gap’s evidence 7, 23, 24, 25, Gap’s evidence 36 through 39, witness II, and SaJ.

Therefore, this part of the Plaintiff’s assertion on the premise that the Plaintiff, not ParkB, lent the above money to ChoCC is without merit.

① On April 19, 2007, the MediationCC prepared a loan certificate stating that the recipient will borrow OOOB by making the recipient an bB and borrowing it. Although the Mediation Committee prepared a loan certificate stating that the recipient will borrow OOB without stating the recipient on May 18, 2007, it appears that the POB was holding the loan certificate, the above OOB was deposited in the name of POB on May 18, 2007, and the above OOB was also deposited in the name of POB on April 30, 2007. In light of the fact that the Mediation Committee written the loan certificate of OOBB as bB on May 18, 2007, the recipient of the loan certificate can be inferred as OOB.

② Unless there is any clear and acceptable reflective evidence that denies the contents of the above loan certificate, the existence and content of the expression of intent in accordance with the contents of the document should be recognized. Although the above OOOO was deposited in the Plaintiff’s name on April 20, 2007, and the above OOOOO was withdrawn from the deposit account in the Plaintiff’s name and deposited in the bank account in the name of the immediately registered CC through substitute transaction, in light of the above circumstances, it can be deemed that ParkB, the representative director of the Plaintiff, would have withdrawn the above money from the Plaintiff’s deposit account and used it as a loan. Based on this, it is difficult to deem that the Plaintiff lent the above loan certificate to ChoCC.

③ The Plaintiff did not include the above OOOO as the Plaintiff’s loan on the financial statements of the business year 2007, but instead appropriated the said money as an advance payment item on the private OOOO business license. In the course of the settlement of accounts of the business year 2011, the Plaintiff included the above OOOO as the raw material expense item and included it in the calculation of losses. As such, the Plaintiff did not assert that it lent money to the ChoCC.

④ On January 12, 2010, ParkB filed a criminal complaint against the Mediation Committee under his/her own name on charges of fraud, and was sentenced to a favorable judgment that ordered the Mediation Committee to pay the above OOOOOO won to him/her even in the lawsuit of loan claim filed by the Changwon District Court Branch 201Gahap1620 and the court 201Gahap1743.

3) Determination as to the assertion of business relevance

A) Article 28(1)4(b) of the former Corporate Tax Act (amended by Act No. 11128, Dec. 31, 2011; hereinafter “Corporate Tax Act”) and Article 53(1) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 23589, Feb. 2, 2012) regulate that interest on loans for the procurement of provisional payments paid by a corporation to a specially related person as deductible expenses shall not be included in deductible expenses. The purpose of this provision is to prevent insolvency of a company by unfairly divulging corporate funds for personal needs of the company, as the interest paid for the financing of provisional payments, etc. without relation to the business is not the cost of creating the corporation’s income, and it is difficult to view it as deductible expenses in terms of the tax accounting because it is not difficult to respond to the income of the corporation. In terms of the tax policy, the purpose of this provision is to prevent the occurrence of insolvency of the company by unfairly divulging corporate funds

Such provisional payments irrelevant to business shall include not only purely meaningful loans, but also loans corresponding to the nature of claims, such as indemnity bonds, etc., and whether they are related to business should be objectively determined based on the purpose of business or business contents of the relevant corporation (see, e.g., Supreme Court Decision 2005Du1558, Oct. 26, 2006).

B) Based on these legal principles, we examine the above recognition.

ParkB withdrawn the OOB from the deposit account in the name of the Plaintiff and lent it to the ChoCC. The Plaintiff is a corporation whose business purpose is the business of manufacturing and installing automated machines and the business of electrical and electronic parts, etc., and the Plaintiff’s representative director, who is a person with a special relationship, withdraws money from the Plaintiff in order to lend money to ParkB to the ChoCC who was in the position of the chairman of the OOB at around 2007 at the time of 207, cannot be deemed as a business act of the ordinary representative director for the company.

Even if ParkB lent money to CC to the Plaintiff to obtain a logistics business right ordered by the GG industry, it cannot be deemed as an act generally acceptable or objectively deemed necessary for business for the formation of friendship or the smooth progress of transactional relations, and even if the loan amount reaches OO members, it is difficult to view that it is within the scope of business activities acceptable by social norms in light of the following: (a) the lending amount without any interest agreement; (b) the lending amount reaches OO members; and (c) it is difficult to view that it is within the scope of business activities acceptable by social norms in light of the fact that the lending of the above CC resulted in a significant increase in profit directly to the Plaintiff due to the lending of the above CC.

Therefore, it is reasonable to regard the plaintiff's paid to ParkB who is a person with a special relationship as a provisional payment to the office of work, and there is no reason for the plaintiff's assertion against this part.

4) Determination as to the assertion of violation of substance over form principle

Article 19(1) of the Corporate Tax Act provides that "deductible expenses shall be the amount of losses incurred by transactions which reduce the net assets of the corporation, except as otherwise provided for in this Act or other Acts." Meanwhile, Article 19(2) of the same Act provides that "deductible expenses shall be losses or expenses incurred in connection with the business of the corporation which are generally accepted as normal or directly related to profits, except as otherwise provided for in this Act or other Acts."

Therefore, the corporate tax taxation principle is not to reflect all losses incurred by the reduction of net assets in the calculation of the tax base and the amount of corporate tax, but to calculate the tax base and the amount of corporate tax after including the ordinary losses or expenses generally recognized as losses or expenses incurred in connection with the business of the relevant corporation, or only those directly related to profits. However, as seen earlier, it is reasonable to deem that the above OOOO as paid to the MediationCC is not related to the Plaintiff’s business. Thus, it cannot be deemed that the disposition of this case, not including it in the calculation of losses, was contrary to the doctrine of ability burden or the principle of substance over form.

Therefore, the plaintiff's assertion on this part is without merit.

5) Judgment on the assertion of the principle of good faith

A) In general, in order to apply the principle of trust and good faith to the acts of the tax authorities in tax and legal relations, the tax authorities should name the public opinion list that is the object of taxpayer trust, the tax authorities’ name of opinion statement is justifiable, and there is no reason for the taxpayer to believe that the name of the opinion list is justifiable, and the taxpayer must act in trust, and the tax authorities should make disposition against the above opinion list to infringe the taxpayer’s interest. If the expression of opinion by the tax authorities is merely a general theoretical opinion statement, the application of the above principle is denied (see, e.g., Supreme Court Decision 2007Du19447, Apr. 29, 2010).

B) In light of such legal principles, even if there was a resolution of the Advisory Committee on Determination of Tax Facts prior to the instant disposition, it cannot be deemed that the Defendant, who is the tax authority, issued a public opinion statement that is trusted to the Plaintiff, a taxpayer, and further, Article 23(1) of the Regulations on the Management of Tax Facts Advisory Affairs provides that “the applicant notified of the result of deliberation on the application for consultation on determination of Tax Facts shall utilize it as a result of the business process,” and does not necessarily stipulate that the business should be carried out according to the result. Thus, the Defendant’s failure to accept the decision of the Advisory Committee on Determination of Tax Facts cannot be deemed as having violated the good faith principle merely because it did not immediately

Therefore, the plaintiff's assertion on this part is without merit.

6) Determination on the assertion of procedural violation, such as a pre-assessment review request

Although the pre-assessment review system, separate from the ex post facto remedy system after the tax assessment, reflects taxpayers' claims in the pre-assessment phase to enhance the effectiveness of the protection of rights, it does not constitute an essential premise for the taxation disposition, such as where the exclusion period of the tax assessment is imminent (see, e.g., Supreme Court Decision 2010Du19713, Oct. 11, 2012).

Furthermore, as seen earlier, after the Defendant rendered a decision to maintain the original disposition on February 21, 2013 according to the result of re-audit, it is merely a decision to revise the tax base or tax amount based on the details revealed in the reason for the decision, and thus, it cannot be deemed that there was a serious procedural error because it is difficult to deem that the Plaintiff did not give the opportunity to request pre-assessment review to the Plaintiff, and thus, it is difficult to deem that there was an unforeseen risk for the Plaintiff. According to the evidence No. 12, according to the notice of decision No. 12, it cannot be deemed that there was no notification of the procedure against which the Plaintiff was dissatisfied with the legitimacy of the taxation disposition, as the content of the review,

Therefore, the plaintiff's assertion on this part is without merit.

3. Conclusion

Therefore, the plaintiff's claim is dismissed in entirety as it is without merit. It is so decided as per Disposition.