Kim Yong-sap (Attorney Nam-su et al., Counsel for the defendant-appellant)

Daejeon Head of the District Tax Office

September 24, 2008

1. Of the instant lawsuits, the part of the claim for revocation of the decision on tax investigation shall be dismissed.

2. A. The portion exceeding KRW 987,508 of the imposition disposition of global income tax of KRW 9,555,180 on May 9, 2006 by the Defendant against the Plaintiff on May 9, 2006;

B. The Defendant limited on June 5, 2006 to the Plaintiff:

(1) impose a tax of KRW 18,553,160 on global income for the year 2001;

(2) the portion exceeding KRW 48,183,647 of the disposition imposing global income tax of KRW 63,733,000 for the 2002;

(3) the portion exceeding KRW 13,264,705 of the disposition imposing global income tax of KRW 27,618,410 for the tax year 2003;

(4) The portion exceeding KRW 4,536,653 in the disposition of imposition of value-added tax of KRW 7,788,430 for a period of one year 201;

(5) the portion exceeding KRW 5,334,817 in the disposition of imposition of value-added tax for a period of two years in 2001;

(6) the portion exceeding 10,801,601 won in the disposition of imposition of value-added tax of 19,105,370 won for a period of one year 2002;

(7) The portion exceeding KRW 8,097,200 in the disposition of imposition of value-added tax of KRW 10,304,390 for the second period of 202;

(8) The portion exceeding KRW 4,405,389 in the imposition disposition of value-added tax of KRW 6,911,550 for a period of one year 2003;

(9) Of the imposition disposition of value-added tax for the second period of 2003 KRW 7,848,120, the part exceeding KRW 6,199,315

Each cancellation shall be revoked.

3. The plaintiff's remaining claims are dismissed.

4. One-half of the costs of lawsuit shall be borne by the Plaintiff, and the remainder by the Defendant.

The investigation and determination of paragraphs (1), (1)-B (1), (3) through (9) of the order and the defendant sent to the plaintiff on March 5, 2007 as stated in the notice of tax investigation sent by the plaintiff on March 5, 2006 shall be revoked. The part of the disposition by the defendant exceeding KRW 26,031,387 of the disposition of global income tax for 63,73,000 for the plaintiff on June 5, 2006 shall be revoked.

1. Details of the disposition;

A. The Plaintiff, a lawyer operating the law office in Seo-gu, Seo-gu, Daejeon, has paid the value-added tax and the global income tax from 2000 to 2004 to the Defendant.

B. The Defendant received information on the tax evasion during the pertinent taxable period from Nonparty 1, who had previously worked as the head of the Plaintiff’s legal office, and conducted a tax investigation on the Plaintiff (hereinafter “first tax investigation”) with respect to the Plaintiff from March 13, 2006 to April 21, 2006. As a result, the Defendant determined that a criminal case among the cases accepted by the Plaintiff was based on the criminal agreement prepared by the Plaintiff’s office, and a civil case was also omitted based on the receipt book of civil cases prepared by the Plaintiff’s office.

(Voting 1)

본문내 포함된 표 부가가치세 과세기간 신고금액 확인 과세표준금액 누락금액 합계 형사사건 민사사건 2000. 1. 127,962,999 146,581,172 18,618,173 12,081,814 6,536,359 2000. 2. 93,658,146 106,994,508 13,336,362 9,336,362 4,000,000 2001. 1 119,089,175 158,434,626 39,345,451 26,099,998 13,245,453 2001. 2 91,454,542 131,236,349 39,781,807 30,081,811 9,699,996 2002. 1. 115,727,261 222,045,425 106,318,164 74,227,262 32,090,902 2002. 2. 61,136,386 121,572,741 60,436,355 47,490,904 12,945,451 2003. 1. 79,492,821 128,555,386 49,063,365 31,272,729 17,790,636 2003. 2. 77,462,110 135,446,021 57,983,911 47,620,287 10,363,624 2004. 1. 56,694,930 147,603,892 90,908,962 88,181,689 2,727,273 2004. 2. 54,981,862 57,618,222 2,636,360 2,636,360 ？ 종합소득세 과세기간 신고금액 확인 총수입금액 누락금액 합계 형사사건 민사사건 2000 221,621,145 253,575,680 31,954,535 21,418,176 10,536,359 2001 217,998,657 297,125,915 79,127,258 56,181,809 22,945,449 2002 187,688,647 354,443,166 166,754,519 121,718,166 45,036,353 2003 165,093,549 272,140,825 107,047,276 78,893,016 28,154,260 2004 120,639,792 214,185,114 93,545,322 90,818,049 2,727,273

(unit, source)

C. The Defendant added the omitted amount to the tax base of value-added tax and the total amount of global income tax, and recognized the necessary expenses for which disbursement was verified instead, and accordingly imposed and notified each of the Plaintiff’s global income tax from 2000 to 2004 and value-added tax from 2001 to 2004 as indicated in the following table 2 (hereinafter “instant disposition”).

(List 2)

본문내 포함된 표 부과일 과세기간 부가가치세 과세기간 종합소득세 2006. 5. 9. ？ ？ 2000. 9,555,180 2006. 6. 5. 2001. 1.기 7,788,430 2001. 18,553,160 2001. 2.기 7,508,810 2002. 1.기 19,105,370 2002. 63,733,000 2002. 2.기 10,304,390 2003. 1.기 6,911,550 2003. 27,618,410 2003. 2.기 7,848,120 2004. 1.기 12,941,740 2004. 2,521,880 2004. 2.기 327,880

(unit, source)

D. On January 25, 2007, the Plaintiff filed a request for a trial with the National Tax Tribunal. On February 5, 2007, the Plaintiff rendered a decision that “the rectification of any erroneous part” was “the rectification of any erroneous part.” Therefore, on February 5, 2007, the Defendant deducted KRW 8,727,273 from the Plaintiff’s tax base of value-added tax and global income tax revenue for 2004, deducted KRW 1,133,584 from the value-added tax for 1,133,584 from the global income tax for 2004, reduced KRW 2,803,349 from the global income tax for 2,804, respectively, and accordingly, refunded the difference that was reduced from the global income tax for 2004 to the Plaintiff.

E. After that, Nonparty 1 again informed the Defendant of the omission of contingent fees, etc. for criminal cases in the first tax investigation while submitting the Plaintiff’s legal office’s criminal receipt book, etc., which, around the beginning of March 2007, the Defendant notified the Plaintiff that “from March 5, 2007 to March 23, 2007 (15 days) of the investigation period, tax items subject to investigation, income tax, value-added tax, etc., and the investigation period from January 1, 2001 to December 31, 2004” should be additionally conducted.

F. On March 6, 2007, the Defendant sent a business trip to the Plaintiff’s law office and issued the taxpayers’ right charter, pledge of integrity, etc., and attempted to initiate the instant tax investigation, but failed to enter the Plaintiff’s counter-explosive investigation.

G. On March 2, 2007, the Plaintiff filed a request for review on the instant tax investigation decision with the Commissioner of the National Tax Service, but was dismissed on March 19, 2007.

[Ground of recognition] Facts without dispute, Gap 1 through 3, 6 through 14, 18, 19, Eul 1 through 25, 27 through 39 (including various numbers), the purport of the whole pleadings

2. Part concerning a request for cancellation of a decision on tax investigation;

A. The parties' assertion

(1) The plaintiff's assertion

Although the Defendant had already conducted an initial tax investigation and reflected the result of the tax disposition by the Plaintiff, the Defendant again decided to conduct the instant tax investigation on the ground that the informant submitted an additional tax receipt book and a criminal case receipt book, etc. However, the above criminal case receipt book is merely a document for convenience in the operation of the law office and does not reflect the exact details of the revenue. As such, it does not comply with the requirements of Article 81-6(2) of the Framework Act on National Taxes that provides that a reinvestigation shall be conducted only when there is clear evidence to acknowledge the suspicion of tax evasion. A tax investigation is a public authority of an administrative agency infringing on the specific rights of the public, and thus, it constitutes a

(2) The defendant's assertion

A tax investigation is not only a preliminary act to promote the appropriateness of disposition by collecting data on specific facts necessary for future disposition based on the right of inquiry and investigation prescribed by tax-related Acts, but it is not a disposition that is subject to lawsuit.

(b) Related statutes;

It is as shown in the attached Form.

C. Determination

(1) The term "disposition of an administrative agency, which is the subject of an appeal litigation, refers to, in principle, an act of an administrative agency under public law, which directly affects the rights and obligations of the people, such as ordering the establishment of rights or the burden of obligations, or directly generating other legal effects with regard to a specific matter, and thus, it does not constitute an act that does not directly change the legal status of the other party or

(2) In collecting taxation data, a series of acts conducted by a tax official by exercising his/her right of questioning and inspection to investigate and verify the facts meeting the taxation requirements and collecting direct and indirect materials necessary for taxation is conducted on the premise of a taxpayer’s consent. However, the other party to the question is indirectly forced to answer questions and undergo inspections through sanctions on false statements, etc. In this sense, the exercise of the right of questioning during a tax investigation can be deemed as an act of fact, the nature of which is the exercise of public authority, and therefore, there is no room to be an administrative litigation at all.

We examine whether the "decision to conduct a tax investigation" as stated in the prior notice of tax investigation itself has the nature of a disposition subject to appeal litigation.

Where a tax official investigates account books, documents, and other articles, etc. for the purpose of the investigation on the national tax, he/she shall notify the taxpayer subject to the investigation of the tax items to be investigated, the period and reason for the investigation, and other matters prescribed by Presidential Decree 10 days prior to the commencement of the investigation. However, in cases of an investigation or prior notice of an offence case, if it is deemed impossible to achieve the purpose of the investigation due to the destruction of evidence, etc., the tax official may initiate the tax investigation without prior notice (Article 81-7(1) of the Framework Act on National Taxes). Thus, in cases of an investigation or prior notice of an offence case, the decision to initiate the tax investigation is not indicated externally through prior notice without exception. Since prior notice is the main purpose of enabling the taxpayer to sufficiently prepare for the taxpayer to undergo the tax investigation with voluntary cooperation in order to facilitate the tax investigation, the prior notice is not an administrative act that directly restricts the rights and duties of the people, but it is merely an internal policy of the tax office to commence the tax investigation prior to the commencement of the tax investigation, and it may be deemed as an exercise of specific duty of the existing tax investigation.

(3) Of the instant lawsuit, the part on the claim for revocation of a tax investigation decision is unlawful.

3. Whether the disposition of imposition is lawful.

A. The parties' assertion

The plaintiff asserts that the disposition of this case is illegal as follows.

First, the receipt book of civil cases is prepared for the convenience of the plaintiff's office's work, and does not properly reflect the details of the refund of fees or part of the litigation costs, so it cannot be considered as the basic data for calculating the plaintiff's income far from the accuracy.

Second, the instant taxation disposition, which was made without considering the fact that some of the contingent remuneration stipulated in the criminal agreement was not paid or returned to the client for reasons such as failure to fulfill the conditions, was unlawful.

B. Determination

(1) Facts of recognition

The following facts may be acknowledged by comprehensively taking account of the overall purport of the arguments in each of the above facts.

(A) The case receipt book of the Plaintiff’s office prepared the case in which the chief executive officer appointed a female employee by dividing it into civil cases and criminal cases. The serial number was attached to each case, and the case was stated next to the acceptance date, the party (the client, contact number), the case name, the contract amount, the deposit amount, and the non-deposit items. The deposit column is written with the amount deposited (the date of payment is stated together) in the remarks column. However, in the remarks column, the additional circumstances after the receipt were not reflected, such as the details of return of the deposited money to the clients, but the contract amount was omitted.

(B) The criminal agreement states the details of the agreement that the Plaintiff entered into with the client when accepting the instant case. On the front, the agreement states the specific details of the agreement amount (in place) and the contingent fee, and on the back, the agreement amount actually received from the client and the amount of the contingent fee are written in accordance with the deposit date. As such, the details of the return are also stated.

(C) On September 2004, Nonparty 1 retired from the office of the Plaintiff’s legal office, and provided the Defendant with a copy of the above criminal agreement and provided the Defendant with information on the fact of tax evasion based thereon. Accordingly, the Defendant, while conducting the first tax investigation, submitted a civil case receipt book, set-off, document keeping (civil, criminal) and bank passbook, etc. in the Plaintiff’s office from 2000 to 2004. Based on this, Nonparty 1 investigated the Plaintiff’s revenue amount by adding up the copies of the above criminal agreement submitted by Nonparty 1.

(D) The method in which the Defendant calculated the specific amount of revenue for civil cases is as follows.

① The amount stated in the column of deposit in each annual receipt book and in the remarks column of the Plaintiff’s actual income, and the amount omitted was calculated in comparison with the “Detailed Statement of Revenue of Attorney-at-Law” prepared by the Plaintiff at the time of filing a tax base return. Although the case is specified in the Statement of Revenue of Attorney-at-Law Cases, if the case itself or the amount of the deposit is omitted, the amount already reported by the Plaintiff was deemed legitimate, and the Plaintiff was excluded from the omission of revenue if the Plaintiff, even though it was indicated in the receipt book of the case, has clarified justifiable cause by resignation

② Of the written vindication submitted by the Plaintiff, the Defendant was three cases. However, the Plaintiff did not accept the Plaintiff’s assertion that the Plaintiff included litigation costs, such as commission and stamp, which are not fees, among the amount that the Plaintiff received from the clients. In order to verify the entries in the receipt book of the case, the actual investigation of the clients was not conducted. In addition, there was a civil agreement made between the clients, and if any, the details thereof were not verified.

③ As a result of the analysis of the details of deposits on the Plaintiff’s deposit passbook, the Defendant waivers to take the remainder as detailed investigation and taxation data on the ground that the account holder’s personal information was generally known, and even if so known, the personal information was conducted in the name of his family members, etc. or many details irrelevant to his/her deposit fees were included. Accordingly, almost all investigations depend on the entry in the receipt book of civil cases.

④ In a national tax proceeding, the Plaintiff submitted evidentiary documents, such as a confirmation of facts prepared by the parties in order to support the assertion that there is a case in which litigation costs, other than fees, are included in the agreed amount, but this assertion was not accepted.

(e) In the case of a criminal case:

Based on the amount entered in the back of the criminal agreement, the plaintiff calculated the plaintiff's income, the plaintiff also recognized the accuracy of the contract, and the plaintiff's assertion on the amount of partial return was accepted, and was reflected in the calculation of the amount of income. In the process, the details of the case at issue raised by the plaintiff are as listed below 3, but no substantial investigation was conducted as to whether the conditions of the contingent fee agreement have been fulfilled.

(List 3)

본문내 포함된 표 과세 년도 피고인 약정금 성공보수 약정 약정서 뒷면 기재 입금 내역 선고일 선고결과 성공여부 공제인정금액 (단위, 원) 2001년 1기 소외 2 외 3인 650만원 소외 3, 소외 4 : 벌금형의 선고가 있을 경우 각 200만 원, 소외 2 : 형의 선고유예 또는 집행유예의 선고가 있을 경우 400만원, 소외 5 : 무죄판결의 경우 100만원 3/19 20만원, 3/22 530만원, 4/18 50만원(소외 5), 6/27 400만원 2001. 7. 6. 소외 3, 소외 4 : 징역 8월에 집행유예 1년/소외 2 : 징역 1년/ 소외 5 : 벌금 50만원 실패 3,181,818 2001년 2기 소외 6 400만원 추후결정 8/20 400만원, 9/12 200만원(성공보수) 2001. 9. 14. 항소기각 실패 1,818,181 2002년 1기 소외 7 330만원 경찰 또는 검찰단계에서 성공한 때 : 270만원, 보석청구허가 된 때 : 270만원, 벌금형 이하 선고 : 270만 원 1/4 150만원, 1/10 180만원, 2/2 500만 원 2002. 2. 7. 벌금 1000만원 일부 성공(270만원 이상 받을 수 없음) 2,090,909 ？ 소외 8 400만원 경찰 또는 검찰단계에서 성공한 때 : 600만원, 보석청구허가 된 때 : 300만원, 형의선고 유예 또는 집행유예의 경우 : 300만원 4/11 400만원, 4/19 300만원 2002. 5. 17. 실형선고 실패 2,727,272 ？ 소외 9 330만원 보석 200만원, 벌금이하 200만원, 선고유예 또는 집행유예 선고 200만원 3/11 330만원, 3/22 220만원 2002. 3. 29. 보석/벌금300만원 성공 ？ ？ 소외 10 440만원 벌금형이하 선고, 형의 선고유예 또는 집행유예의 선고가 있는 때 300만원(약정서 4조 중 4호 '벌금형의 선고가 있은 때' 해당 란에 300만원이 기재되어 있기는 하나, 4호 뿐 아니라 5호 '형의 선고유예 또는 집행유예의 선고가 있는 때'도 묶어서 의뢰인 소외 11의 서명이 되어 있다) 6/15 440, 7/26 300만원 2002. 7. 26. 징역 10월에 집행유예 2년 성공 ？ ？ 소외 12 550만원 성공보수 추후 결정함 6/17 330만원, 6/22 220만원, 7/15 700만원 2002. 7. 26 징역 2년6월에 집행유예 4년 불분명 6,363,636 소계 ？ ？ ？ ？ ？ ？ ？ 11,181,817 2003년 2기 소외 13 330만원 약정없음 8/11 330만원, 8/26 200만원(성보) 2003. 8. 26. 징역 1년 6월에 집행유예 3년 불분명 1,818,181 2004년 1기 소외 14 330만원 선고유예 또는 집행유예 500만원 5/17 330만원, 6/1 500만원 2004. 8. 20. 징역 3년 6월 실패 4,545,454

(2) For civil cases:

When correcting errors or omissions in the details of a taxpayer's tax base and amount of tax, etc. due to an error or omission, evidence such as books, etc., however, if it is recognized that there are errors or omissions in the details of a taxpayer's return through other data and it is possible to correct them through other data.

The receipt book of a civil case, which served as the basis for the instant taxation, is ordinarily prepared by the employee of the Plaintiff’s legal office on the basis of free will, and the details of the deposit amount of the contract are written in detail, so it can be a reliable and reliable taxation data once. However, in some cases, there is no prior agreement document, and considering the nature of the case, it is not a book or a normal accounting book under tax law, but a document that comprehensively manages whether the case has been actually received for the convenience of the attorney’s office. Therefore, in order to grasp the overall exact contents including the progress situation after the receipt of the case, it is insufficient to record the receipt book of the civil case in order to understand the entire exact contents, and further, the additional detailed detailed investigation into the financial data secured by the Plaintiff, civil agreement and the actual comparison with the client, and the detailed process for the confirmation of the accuracy of the confirmation document submitted by the Plaintiff.

In most cases, even if the plaintiff received litigation costs separately from the client's fees, and it is true that the plaintiff omitted the tax return of considerable portion of the fee income entered in the receipt book of civil cases, in order to properly calculate the fee revenue by the defendant's method, the amount entered in the receipt book of civil cases is correct and confirmed as the final revenue. However, since the amount partially returned is included or the minimum confirmation investigation on the essential part is omitted, it is difficult to view that all of the fees entered in the receipt book of this case as the plaintiff's revenue is the plaintiff's revenue. Therefore, it cannot be deemed as the accurate revenue for which the whole difference between the amount entered in the receipt book of this case and the amount of the attorney's revenue statement already submitted to the tax office is omitted, it is unlawful to calculate the tax base by including it in the total amount of income of each corresponding year, and it is impossible to calculate the specific tax base of each corresponding year and the amount of tax based on this circumstance. Accordingly, the disposition of this part cannot be revoked.

(3) In the case of a criminal case

In relation to the contingent fees under Table 3, the remaining two cases except for the cases where the conditions of the contingent fees under the initial agreement are deemed to have been satisfied among the criminal cases where the Plaintiff asserted that the conditions of the contingent fees under the initial agreement were met (the case of Nonparty 2, Nonparty 3, and Nonparty 6, February 2001, Nonparty 7, 8, 12, February 2002, Nonparty 13, January 2003, and January 14, 2004), or where the conditions were not satisfied, or where it is unclear whether the conditions were met or not. According to the above evidence, the Plaintiff appears to have received the contingent fees in advance from the clients in criminal cases before the judgment was rendered, but it is highly probable that the Plaintiff would return the money to the client, and thus, it is necessary to conduct a specific confirmation and investigation. However, the Defendant did not undergo this procedure, so it is not enough to recognize the remainder of the pertinent contingent fees calculated by the Plaintiff as 100 each of the "amount of the contingent fees" in the above table 3.

(4) Calculation of a legitimate tax amount

(A) The tax base of value-added tax and the total amount of global income tax confirmed as a result of the initial tax investigation are as indicated below in the “tax base for confirmation” and “total amount of revenue for confirmation,” and the tax base and amount of revenue for each pertinent taxable period determined as unlawful by this court is as follows: (a) inasmuch as the amount of deduction for private accidents and the amount of deduction for criminal cases are the same as the amount of deduction for the latter; (b) when calculating a legitimate tax base and amount of revenue, the amount of “justifiable tax base

(Voting 4)

본문내 포함된 표 부가가치세 과세기간 신고금액 확인 과세표준 금액 (A) 민사사건 공제액(B) 형사사건 공제액 (C) 정당한 과세표준(A-B-C) 2001. 1 119,089,175 158,434,626 13,245,453 3,181,818 142,007,355 2001. 2 91,454,542 131,236,349 9,699,996 1,818,181 119,718,472 2002. 1. 115,727,261 222,045,425 32,090,902 11,181,817 178,772,706 2002. 2. 61,136,386 121,572,741 12,945,451 ？ 108,627,290 2003. 1. 79,492,821 128,555,386 17,790,636 ？ 110,764,750 2003. 2. 77,462,110 135,446,021 10,363,624 1,818,181 123,264,216 종합소득세 과세기간 신고금액 확인 총수입금액(A) 민사사건 공제액(B) 형사사건 공제액(C) 정당한 수입금액(A-B-C) 2000 221,621,145 253,575,680 10,536,359 ？ 243,039,321 2001 217,998,657 297,125,915 22,945,449 4,999,999 269,180,467 2002 187,688,647 354,443,166 45,036,353 11,181,817 298,224,996 2003 165,093,549 272,140,825 28,154,260 1,818,181 242,168,384

(unit, source)

(B) On the basis of the legitimate tax base and revenue amount, when calculating the legitimate tax amount for each taxation period for which the Plaintiff seeks revocation, it is as listed below 5:

(Voting 5)

본문내 포함된 표 부가가치세 과세기간 2001. 1기 2001. 2기 2002. 1기 2002. 2.기 2003. 1기 2003. 2기 과세표준 142,007,355 119,718,472 178,772,706 108,627,290 110,764,750 123,264,216 매출세액 14,200,735 11,971,847 17,877,270 10,862,729 11,076,475 12,326,421 매입세액 95,984 57,127 174,473 220,977 276,254 274,838 차가감계 14,104,751 11,914,720 17,702,797 10,641,752 10,800,221 12,051,583 공제세액 ？ 128,000 ？ 75,000 143,418 76,000 기납부세액 11,812,933 9,028,415 11,398,253 5,817,661 7,529,530 7,395,373 가산세액 2,244,835 2,576,512 3,448,836 3,348,109 1,278,116 1,619,105 정당세액 4,536,653 5,334,817 9,753,380 8,097,200 4,405,389 6,199,315

본문내 포함된 표 종합소득세 과세기간 2000 2001 2002 2003 수입금액 243,039,321 269,180,467 298,224,996 242,168,384 소득금액 105,197,826 100,753,756 153,362,142 108,862,181 소득공제 7,752,000 8,971,080 10,657,240 11,774,390 과세표준 97,445,826 91,782,676 142,704,902 97,087,791 세율 0.40 0.40 0.36 0.36 산출세액 25,978,330 23,713,070 50,203,765 23,251,605 결정세액 25,978,330 23,713,070 50,203,765 23,251,605 신고불성실 ？ - 4,140,788 1,264,458 납부불성실 ？ - 10,792,928 2,052,768 가산세액계 504,835 - 14,933,716 3,317,226 총결정세액 26,483,165 23,713,070 65,137,480 26,568,831 기납부세액 25,495,657 24,916,717 16,953,833 13,721,575 정당세액 987,508 0 48,183,647 12,847,256

(unit, source)

(C) Of the instant disposition, the part of the disposition of imposition of global income tax on 2001 to 2003 and the part of the disposition of imposition of global income tax on 2000 to 203, which exceeds each pertinent tax amount on 5’s Schedule, should be revoked. However, the disposition of imposition of global income tax on 2001 is deemed to be zero won, and thus, the disposition of imposition of global income tax on 2001 is entirely revoked. In addition, the Plaintiff seeks to revoke only the portion exceeding 10,801,601 out of the assessed global income tax on 1002, and the Plaintiff seeks to revoke only the portion exceeding 13,264,705 won. Accordingly, each disposition of imposition is revoked as described in paragraph (2) of this Article.

4. Conclusion

In the lawsuit of this case, the part of the claim for revocation of the tax investigation decision is dismissed as unlawful, and the plaintiff's claim for revocation of the disposition is partially accepted within the scope of the above recognition.

[Attachment]

Judges Hwang Sung-ju (Presiding Judge)