1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

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

1. The grounds for admitting and amending the judgment of the court of first instance are as stated in the reasoning of the judgment of the court of first instance, except where the grounds for admitting and modifying this case are used by the court of first instance as follows. Thus, they are cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Supplementary Use]

4. Determination on the conjunctive claim

A. According to Articles 55(1) and 56(2) of the Framework Act on National Taxes, where a lawsuit seeking revocation is instituted against a disposition made under the Framework Act on National Taxes or other tax-related Acts, a prior trial procedure, such as a request for evaluation or adjudgment, should be conducted.

In addition, Article 2(2) of the Framework Act on National Taxes stipulates the National Tax Collection Act as one of the tax laws, and the National Tax Collection Act provides for the seizure of claims as a procedure for the disposition on default under Articles 24(1) and 41 of the same Act. As such, the instant disposition on seizure constitutes a disposition on default under the National Tax Collection Act, which constitutes a “disposition under the tax law” under Article

Therefore, in order to file a lawsuit seeking revocation of the instant attachment disposition, it shall undergo the prior trial procedure under Article 56(2) of the Framework Act on National Taxes.

(See Supreme Court Decision 71Nu63 delivered on February 22, 1972). Meanwhile, even in a case where an administrative suit is filed to seek revocation in the sense of declaring the invalidity of an administrative disposition, it shall meet the requirements for filing a revocation suit, such as the transfer of an administrative appeal and the observance of the filing period.

(See Supreme Court Decision 84Nu175 Decided May 29, 1984). In other words, considering the entire purport of the pleadings in the statement of evidence Nos. 1, 2, 8, 9, and 10 returned to the instant case and the statement of Evidence Nos. 1, 1-2, 8, 9, and 10, the Defendants sent to the Plaintiff a document stating “Woo” around March 2017, and the said document was served on the Plaintiff on March 24, 2017. When the Plaintiff was served with the foregoing document, the Defendants sent to the Plaintiff on April 5, 2017.