1. All appeals filed by the plaintiff and the defendant are dismissed.

2. Of the appeal costs, the part relating to the Plaintiff’s appeal is the Plaintiff.

1. Acknowledgement of the reasoning of the judgment of the court of first instance is the same as the written reasoning of the judgment of the court of first instance except for the following parts to be cited or added. Thus, 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.

Each "local income tax (special collection pro rata)" in Part 4, 12, 13, 14, 15, 16, and 17 of the judgment of the first instance court shall be deemed to be "resident tax (special collection pro rata) to be corporate tax", "Article 29 (2) 2 of the former Local Tax Act" in Part 16, "Article 29 (2) 1 of the former Local Tax Act" shall be deemed to be "Article 29 (2) 1 of the former Local Tax Act", "Article 197-3 of the former Local Tax Act" in Part 17, "Article 179-3 of the former Local Tax Act" shall be deemed to be "Article 179-3 of the former Local Tax Act", and "the relevant increased or corrected disposition" in Part 18, 12 shall be deemed to be "the increased or corrected disposition of corporate tax (collection

Part 18. The following shall be added to the decision of the first instance, 19.

The above Supreme Court Decision 2002Du7852 Decided July 8, 2004 cited on the ground that the above assertion was supported by the defendant. However, the above Supreme Court Decision 2002Du7852 Decided the corporate tax to be determined and paid at the time of the decision or rectification when the head of a tax office makes a correction on the grounds that there is an error or omission in the contents of the "corporate tax declared and paid" as a result of a tax investigation, and the liability for the payment of corporate tax to be imposed on the resident tax (special collection) which is to be

In addition, the defendant asserts that the resident tax to be collected specially on the dividend income of this case shall be established only when the increase or decrease of corporate tax is made, and the exclusion period for imposition of ten years shall apply to the defendant's "Fraud and other unlawful acts". However, as seen earlier, the resident tax to be collected specially on the dividend income of this case is automatically determined at the same time as the establishment of law is established.