1. The judgment of the court of first instance is modified as follows.

On December 2, 2016, the defendant belongs to the plaintiff in 2009.

1. The reasoning of the judgment of the court of first instance, citing this case, is the same as the part of the judgment of the court of first instance, except for the following parts to be filled or added. Thus, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

Article 2(4)1 of the former Enforcement Decree of the Income Tax Act (Article 2(4)1 of the former Enforcement Decree of the Income Tax Act) provides that "The plaintiff shall report the income received from the Hong Kong corporation of this case to the person in charge of the operation of the Hong Kong corporation of this case who has received tax-free income and the amount of taxable income as an executive officer shall be paid." The first instance judgment shall be followed by the following: "The first instance judgment Nos. 16 through 17 of the first instance judgment shall be followed up to 17 of the first instance judgment."

1. The assertion that a nonresident should be recognized as a non-resident, since the person has an occupation that requires him/her to be residing abroad for not less than one year and has no address in the Republic of Korea.

(1) However, according to the structure and contents of Article 2(1) and (3) of the former Enforcement Decree of the Income Tax Act and Article 2(1) of the instant provision, the instant provision is a provision that embodys the abstract standard of address under Article 2(1) of the former Enforcement Decree of the Income Tax Act to determine by objective facts of living relationship, such as the existence of a family living together in Korea and of a property located in Korea. Even if the instant provision provides occupation as the criteria for determining address, this is merely a place in which he/she works for maintaining his/her livelihood.