1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff, as a permanent resident of private placement, obtained financial income of KRW 254,847,00 from domestic financial institutions, including the National Bank of Korea, in 2010 (hereinafter “instant financial income”). However, the pertinent financial institution withheld income tax on the instant financial income, and the Plaintiff did not separately file a global income tax return.

B. On November 1, 2014, the Defendant issued the instant disposition imposing global income tax of KRW 48,16,760 (including additional tax) on the ground that “the Plaintiff has resided in Korea for at least one year, and has sustained financial income in Korea, and thus constitutes “resident” under the former Income Tax Act (amended by Act No. 10408, Dec. 27, 2010; hereinafter the same) on the ground that the instant financial income, which was subject to separate taxation as a non-resident, was added to global income for the year 2010 (including additional tax).

C. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on November 24, 2014, but was dismissed on February 24, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, 3, Eul evidence 1 (including each number), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion that his stay in Korea from 2009 to 2012 is not based on the intention or purpose to move his base of living to the Republic of Korea, but due to the inevitable reasons such as treatment and recuperation by the Plaintiff and his spouse. The Plaintiff’s stay in Korea from 2009 to 2012 is merely 102 days if the number of waiting days for medical treatment and the number of days of domestic medical care according to the above circumstances were excluded, and thus, the Plaintiff does not constitute

Therefore, the instant disposition is unlawful on a different premise.

(b) as shown in the attached Form of the relevant statutes;

C. On June 4, 1982, the plaintiff was cancelled on June 4, 1982 the resident registration was cancelled on April 2004.