1. Of the judgment of the court of first instance, the part against the defendant shall be revoked, and all the plaintiffs' claims corresponding to the revoked part shall be revoked.

1. The reasoning of the judgment of the court of first instance cited in this case is as stated in the reasoning of the judgment of the court of first instance, except where part of the reasoning of the judgment of the court of first instance is used as follows. 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.

[Supplementary part] The 10th 16th 10th 16th 16th 16th 207 letter of judgment of the court of first instance shall be written as follows.

The plaintiffs asserts to the effect that "the acceptance of this case shall be null and void if the trust of this case is merely a management trust, and therefore the disposition of this case shall be null and void as a taxation disposition on the facts that have not occurred from the beginning of this case."

However, the acceptance of this case cannot be deemed immediately null and void solely on the ground that the instant trust constitutes a management trust.

We cannot accept this part of the plaintiffs' assertion.

) The 10th sentence of the first instance judgment, the 17th to 12th sentence, the 10th sentence, the 17th sentence, and the 5th sentence are as follows.

C. Determination on imposition of additional tax under tax law is an administrative sanction imposed as prescribed by the Act in cases where a taxpayer violates the duty to report and pay taxes without justifiable grounds in order to facilitate the exercise of the right to impose taxes and the realization of tax claims. Thus, the imposition of additional tax under tax law should be imposed as to the failure to perform the duty under tax law unless there are justifiable grounds for not being able to cause the taxpayer’s failure to perform the duty, such as where there are circumstances where it is unreasonable for the taxpayer to be deemed that he/she was not aware of the duty, or where it is unreasonable for the taxpayer to expect the performance of the duty to pay taxes, etc. (see Supreme Court Decision 2001Du4849, Nov. 8, 2002). In addition, in imposing additional tax, the taxpayer’s intentional negligence or negligence is not considered, and the site, error, etc. of statutes are inconsistent with the duty of breach of duty.