1. All appeals filed by the plaintiffs are dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance concerning this case is as follows: (a) the Defendant’s “Defendant” in the judgment of the court of first instance shall be deemed to be “Defendant”; and (b) the Plaintiffs’ assertion in the trial is identical to the ground of the judgment of the court of first instance, except for adding the following judgments as to the matters alleged in the judgment of the court of first instance; and (c) thereby, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and

2. Additional matters to be determined;

A. The Plaintiff’s assertion 1) The tax authority issued a business registration certificate indicating the “B” store’s business operation registration application with the same content as the instant business establishment without correcting the previous non-taxation practice and expressing the public opinion that these stores are not subject to the individual consumption tax, on this premise. The Plaintiffs trusted this opinion list of the tax authorities, and did not pay the individual consumption tax on the instant business establishment. The Defendants were against this opinion list, and thus, were unlawful in violation of the principle of trust and good faith (the principle of trust and good faith). (2) The tax authority imposed individual consumption tax on the stores carrying on the same business as the instant business, including the instant business establishment for a considerable period from 2011 to 2015. The Defendants were subject to non-taxation practice without expressing their intent to impose the individual consumption tax in the future by correcting the previous non-taxation practice, and thus, each of the instant dispositions in violation of the principle of prohibition of retroactive taxation in accordance with the non-taxation practice.

3) Since the Plaintiffs did not know that they were liable to pay individual consumption tax, the penalty tax of each of the instant dispositions is unlawful at least. (B) Determination 1) As to the assertion of violation of the principle of trust and good faith (the principle of trust and good faith).