1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1..

1. Details of the disposition;

A. The Plaintiff is a law firm to which B, C, and D belong, and the attorneys registered as a certified tax accountant as follows.

On December 26, 2006, December 26, 2006, 1B of the date of renewal of the registration of a certified tax accountant by the name certified tax accountant registration number No. 1 B of the date of registration of the certified tax accountant, and December 11, 2006, C of December 26, 2001, DD on December 3, 2006.

From November 200, the Plaintiff applied for designation as a conciliation team that can prepare a tax settlement statement pursuant to Article 50-3(3) of the Enforcement Rule of the Corporate Tax Act and Article 65-3(3) of the Enforcement Rule of the Income Tax Act and received the designation of a conciliation team from the Defendant. On December 30, 2010, the term of validity was designated as a conciliation team until December 31, 201.

C. On July 14, 2010, the Defendant received from the Minister of Strategy and Finance a reply from the Minister of Strategy and Finance that a law firm is not included in the conciliation team that can prepare a tax settlement statement under Article 50-3(2) of the Enforcement Rule of the Corporate Tax Act and Article 65-3(2) of the Enforcement Rule of the Income Tax Act. On April 4, 2011, the Defendant notified the Plaintiff of the revocation of the designation of the tax agency conciliation team on the ground that “Law Firm is not subject to designation of the conciliation team under Article 50-3(2) of the Enforcement Rule of the Corporate Tax Act and Article

On November 28, 2011, the Plaintiff filed an application with the Defendant to designate the Plaintiff as a conciliation team. On December 26, 2011, the Defendant issued a disposition of refusal to designate a conciliation team (hereinafter referred to as “instant disposition”) on the same grounds as the foregoing paragraph (c).

[Reasons for Recognition] Unsatisfy, Gap evidence Nos. 1 through 4, 6 (including virtual numbers), Eul evidence Nos. 1, 2 and 3, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion (1) Article 50-3(2) of the Enforcement Rule of the Corporate Tax Act and Article 65-3(2) of the Enforcement Rule of the Income Tax Act are contrary to the Certified Tax Accountant Act, while exceeding the delegation scope of the Enforcement Decree of the Corporate Tax Act and the Enforcement Rule of the Income Tax