1. All appeals filed by the plaintiffs are dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

The purport of the claim and appeal is the purport of the appeal.

1. The grounds for admitting and amending the judgment of the court of first instance are as stated in the reasoning of the judgment of the court of first instance, except for adding the following parts to the 8th page 3 following the second instance judgment. Thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Additional Part] The plaintiffs asserts to the effect that "the defendant's pre-announcement of taxation without a on-site confirmation investigation violates Article 63-14 (2) 2 of the former Enforcement Decree of the Framework Act on National Taxes."

Article 81-15(1)2 of the former Framework Act on National Taxes provides, “A person who has received prior notice of taxation prescribed by Presidential Decree may request a head of a tax office or the director of a regional tax office who has received the notice within 30 days from the date of receipt of the notice to examine the legality of the notice.” Article 63-14(2) of the former Enforcement Decree of the Framework Act on National Taxes (amended by Presidential Decree No. 29534, Feb. 12, 2019) provides, “A prior notice of taxation prescribed by Presidential Decree” means any of the following subparagraphs. Meanwhile, Article 81-15(1)2 of the former Enforcement Decree of the Framework Act on National Taxes provides, “A prior notice of taxation shall be issued by the head of a tax office or the director of a regional tax office based on the

However, in light of the purport and text of the above relevant laws and regulations, Article 63-14(2)2 of the former Enforcement Decree of the Framework Act on National Taxes merely interpreted the taxation data for persons other than the relevant taxpayer who is confirmed in the tax investigation and the on-site investigation, and does not necessarily mean that the said provision requires a local inspection when giving notice of tax advance notice.

We cannot accept this part of the plaintiffs' assertion.

2. Conclusion, the plaintiffs' objection.