1. The plaintiff (appointed party)'s appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff (Appointed Party).

1. The reasons for the acceptance of the judgment of the court of first instance are as follows. The grounds for the rejection of the judgment of the court of first instance are as follows: (a) with respect to the assertion that the plaintiff emphasizes or adds to the court of first instance, the plaintiff added the following “2. Additional Judgment”; (b) As such, it is identical to the reasons for the judgment of the court of first instance. Accordingly, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and

(Ma) The Defendant imposed an unfair under-reported additional tax pursuant to Article 47-3(2) of the former Framework Act on National Taxes (amended by Act No. 9911, Jan. 1, 2010) on the ground that D, as alleged by the Plaintiff, filed a return of tax base lower than that to be reported by unjust methods on the transfer of the instant sales right, but this also applies to each of the instant states, even if the Defendant imposed an unfair under-reported additional tax pursuant to the former Framework Act on National Taxes (amended by Act No. 9911, Jan. 1, 2010).

Article 47-2(2)1 of the Framework Act on National Taxes stipulates that if a taxpayer has a tax base without filing a return by unjust means, an amount of penalty taxes without filing a return shall be added to or deducted from a refundable tax amount, and Article 47-3(2)1 of the former Framework Act on National Taxes provides that if a taxpayer has a tax base under filing a return by unjust means, an amount of penalty taxes without filing a return shall be added to

In addition, Article 47-2 (2) of the former Framework Act on National Taxes defines the meaning of "unfair method", which is a common requirement for unfair non-reported and unfair under-reported additional taxes, as "the method prescribed by the Presidential Decree, which violates the duty to report the tax base or amount of national tax on the basis of the concealment or disguise of all or part of the fact that serves as the basis for calculating the tax base or amount of national tax", and the delegation of such duty by the taxpayer.