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

The defendant belongs to the plaintiff in 2009, which was made on June 27, 2012.

1. Details of the disposition;

A. From December 7, 2009, the Plaintiff is registered as the representative director of B Co., Ltd. (hereinafter “instant company”) that carries on the business of importing and selling automobiles from December 7, 2009.

B. On September 201, the head of Seocho District Tax Office: (a) around 2009, based on non-conforming data to the tax invoice of value-added tax of the instant company; (b) increased the value-added tax of KRW 4,433,846 on 209 and KRW 7,303,03,030 on 1, 2010 and value-added tax of KRW 26,963,993 on 2, 2010; (c) added the omitted proceeds from return to the gross income of KRW 4,458,973 and corporate tax of KRW 2010 on 2009 for the business year when the omitted proceeds from return were added to the gross income; and (d) decided to notify the change in the amount of income to be added to the bonus of the Plaintiff.

Around that time, the head of the Seocho District Tax Office notified the head of the Song District Tax Office (the Enforcement Rule of the Organization of the National Tax Service and its affiliated agencies, amended by Ordinance of the Ministry of Strategy and Finance No. 350 on May 9, 2013, and the Defendant succeeded to his/her authority; hereinafter referred to as the “Defendant”) of the data on assessment of changes in the income

C. On June 5, 2012, the Defendant adjusted each of the global income tax of KRW 10,426,310 (including additional tax) and global income tax of KRW 115,902,840 (including additional tax) for the year 2009, respectively.

On June 12, 2012, the Defendant sent a tax payment notice on the global income tax (hereinafter “instant tax payment notice”) by registered mail to Songpa-gu Seoul apartment or D (hereinafter “instant domicile”) which is the Plaintiff’s resident registration address, but returned on June 18, 2012, the Defendant changed the payment deadline (from June 30, 2012 to July 25, 2012) and served the instant tax payment notice by publication on June 27, 2012.

(hereinafter above, the disposition imposing global income tax for the year 2009 and 2010 is referred to as “instant disposition”). D.

On March 6, 2017, the Plaintiff filed an appeal with the Tax Tribunal on the instant disposition.