The plaintiff's appeal is dismissed.

Expenses for appeal shall be borne by the plaintiff.

Purport of claim and appeal

The judgment of the first instance.

1. The reasoning of the judgment of the court of first instance citing the instant case is as follows, and the judgment of the plaintiff emphasizing or newly emphasizing as the grounds for appeal is as stated in the reasoning of the judgment of the court of first instance, except for adding the judgment as stated in paragraph (2) below, thereby citing it as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Supplementary or additional parts] Part 3 of the judgment of the court of first instance refers to the "Seoman Tax Code" in Part 1 of the judgment of the court of first instance as the "Seoman Tax Code".

On the third side of the judgment of the first instance, the term “locked” shall be added to the second part of the judgment of the second instance after “1 November 22, 2017.”

See evidence B No. 1 of the first instance judgment 3-9 of the first instance judgment: “Calculation of KRW 71,487,162, and adding KRW 157,200 to the above KRW 1,57,200,000.” The Plaintiff calculated KRW 71,487,162, and added KRW 6,442,42,423, 157,200 to the additional tax reported by the Plaintiff, etc. at the time of filing a revised return on global income tax for the year 2016.”

On May 15, 2019, the part 7 of the first instance judgment, i.e., “Defendant” through “the fact that the Defendant filed an application for early decision,” i.e., “the fact that the Defendant rendered a prior notice of taxation (Evidence A 4-3) on May 15, 2019, in relation to the previous disposition of this case, stating the tax base, calculated tax amount, and estimated amount of tax assessed, and the Defendant issued a prior notice of taxation (Evidence A-6) on October 1, 2019, stating the tax base, calculated tax amount, and estimated amount of tax assessed, to the Plaintiff.”

The Article 1 of "Article 1" in the 8th sentence of the first instance judgment shall be deemed to be "paragraph 1".

Article 26-2 (2) of the former Framework Act on National Taxes shall be amended to "Article 26-2 (1) 2 of the former Framework Act on National Taxes" in Article 9 of the first instance judgment.

The following shall be added between the 9th sentence of the first instance judgment and the 17th sentence:

On the other hand, the plaintiff.