1. The instant lawsuit shall be dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

We examine the legitimacy of the lawsuit.

The existence of administrative disposition, which is the object of litigation in administrative litigation, is an ex officio matter as a litigation requirement and can not be a confession.

(2) If the Plaintiff did not pay the non-tax revenue by the specified deadline, the Plaintiff’s disposition of imposition of KRW 21,402,430 for non-performance penalty against the Plaintiff on May 20, 2016 is revoked. However, there is no evidence to deem that the Defendant imposed the non-performance penalty against the Plaintiff on May 20, 2016 (Article 1 of the Inheritance Tax Act), and the Defendant merely provided the Plaintiff with the “pre-announcement of attachment due to non-tax in arrears,” and did not impose the non-tax revenue penalty. The foregoing pre-announcement of attachment merely provided the notification that the Plaintiff would seize the Plaintiff’s property without paying the non-tax revenue by the specified deadline, which alone does not directly affect the Plaintiff’s rights and obligations or legal status, and thus, does not constitute an administrative disposition, and thus, is unlawful.

Even if the Defendant considers that he/she seeks revocation of the disposition of imposition of KRW 10,900,00 for non-performance penalty (Evidence Nos. 2 and 3; hereinafter “Disposition of imposition for non-performance penalty for 2014”) imposed on the Plaintiff on November 6, 2015, and the disposition of imposition of KRW 10,460,00 for non-performance penalty (Evidence No. 6 and 8; hereinafter “Disposition of imposition for non-performance penalty for 2015”) imposed on December 31, 2015, he/she shall file a revocation lawsuit within 90 days from the date he/she becomes aware of the disposition (Article 20(1) of the Administrative Litigation Act). The Plaintiff did not know that the disposition of imposition for non-performance penalty for 2014 was made on December 30, 2015; the Plaintiff did not know that there was a disposition of imposition for non-performance penalty for 2015 for 200,000 for the entire pleadings.