Seoul High Court 2011Nu3367 (22 March 22, 2012)

(D) If a lawsuit that does not meet the requirements of administrative appeals is illegal, it shall be deemed to be unlawful.

(Main) The plaintiffs' petition for a trial was filed after the lapse of the period of 90 days in entirety. Thus, the lawsuit in this case is illegal because it does not meet the requirements of the administrative appeal transfer.

Article 56 of the Framework Act on National Taxes

2012du8373 Disposition of revocation of Value-Added Tax Imposition

Kim XX et al.

Head of Namyang District Tax Office

Seoul High Court Decision 2011Nu33367 Decided March 22, 2012

All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but their arguments on the grounds of appeal by the appellant fall under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal, and therefore, all of the appeals are dismissed under Article 5 of the same Act. It is so decided

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final