1. The part against the defendant in the judgment of the court of first instance shall be revoked, and the plaintiff's claim corresponding to the revoked part shall be dismissed.

1. The reasoning of the judgment of the court of first instance is as follows, or the reasoning of the judgment of the court of first instance is as follows, except for the addition of the judgment of the court of first instance as to the plaintiff's argument in the court of first instance to the following Paragraph 2, and thus, it is consistent with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

In addition, the number of pages 6 through 11 shall be as follows:

2) The legislative purport of Article 47-2(2) of the former Framework Act on National Taxes concerning an unfair non-reported penalty tax is to impose a tax on the tax authority in a case where there is a fraudulent act such as making it difficult to find any fact that serves as the basis for calculating the tax base or the amount of national taxes or forging false facts.

Since it is difficult to discover the facts and exercise the right of imposition, imposing heavy sanctions on taxpayers who violate the duty to report the tax base or the amount of tax in such unlawful way, the unlawful act mentioned in this context refers to a deceptive scheme or other active act that makes it impossible or considerably difficult to impose or collect tax.

In addition, the purpose of legislation under Article 26-2 (1) 1 of the former Framework Act on National Taxes is the taxation on national taxes.

In cases where it is difficult to discover the facts or there is any fraudulent act such as creating false facts, it is difficult to expect the exercise of the imposition right by the tax authorities as it is difficult to expect the exercise of the imposition right because it is difficult for the tax authorities to find the omission report, unlike the simple absence of report.

Therefore, a person who purchased and resells real estate takes part in the preparation of a sales contract as if he/she entered into a direct sales contract between a seller and a final buyer, and further, the transfer of ownership is made directly from a seller in the future of the final buyer.