The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined.

1. According to Article 18 of the Framework Act on Local Taxes, tax officials must perform their duties in good faith and sincerity.

In general, in order to apply the principle of trust and good faith to the tax authority's acts in tax law relations, ① the tax authority must express the public opinion that is the subject of trust to taxpayers, ② the taxpayer's reliance on the tax authority's reliance on the tax authority's reliance on the tax authority's reliance on the tax authority's reliance on the tax authority's reliance on the taxpayer's reliance on the tax authority's reliance on the tax authority's reliance on the tax authority's reliance on the

(See Supreme Court Decisions 84Nu593 delivered on April 23, 1985, 2008Du1115 delivered on June 12, 2008, etc.). Although the public opinion statement of a tax authority needs to be made explicitly or implicitly by a tax official in a position of a specific responsibility in principle, the principle of trust and good faith or the principle of gold-competing is applicable to special cases where the protection of taxpayer's trust is deemed consistent with the justice and equity, and there is a key element of the legal doctrine in that even if there are special circumstances where the protection of taxpayer's trust is deemed consistent with the justice and equity. Thus, in determining whether there was a public opinion statement of a tax authority, one of the above requirements, the determination must be made by the substance in light of the organization and duties of a person in charge, specific circumstances under which the relevant speech and behavior was made, and the taxpayer's trust possibility thereof.

(see, e.g., Supreme Court Decisions 94Nu12159, Jun. 16, 1995; 2007Du25060, Apr. 24, 2008). 2. A

The lower court shall accept and add some of the reasons for the judgment of the first instance and add or supplement them as follows.