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. As to this case, the reasoning of the first instance court does not provide for the following reasons: (i) even though the first instance court’s 6th judgment “this case’s disposition,” which was made after both the Framework Act on National Taxes and the National Tax Collection Act amended, is less than the end of the procedure for the disposition on default; and (ii) the meaning of the procedure for the disposition on default as an internal administrative procedure to resume the procedure for the disposition on default; (iii) such disposition on default and its cancellation cannot be deemed to directly affect the rights and obligations of the taxpayer or delinquent; and (ii) the National Tax Collection Ordinance does not provide for “the revocation of the disposition on default shall be notified to the delinquent taxpayer,” as prescribed by Article 84(3) of the former Enforcement Decree of the Framework Act on Local Taxes (wholly amended by Presidential Decree No. 27958, Mar. 27, 2017), it is difficult for the Plaintiff to fully cancel the procedure for the disposition on default and to fully cancel the right to the disposition on default as it is under the Local Tax Collection Act.