1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

The reasoning of the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for partial modification as follows. Thus, it is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The tending part of the decision of the court of first instance shall be replaced by the following contents from 5th to 6th 13th son of the decision of the court of first instance:

1) Article 45-2 (2) of the former Framework Act on National Taxes provides that "a person who has received the determination of the tax base and amount of national taxes may file a request for correction within two months from the date on which he/she becomes aware of the occurrence of any of the following grounds." Thus, a request for correction filed after the lapse of the above period for filing a request for correction is unlawful and the tax authority does not have a duty to determine or correct the tax base and amount of tax or to take a disposition of refusal. Thus, even if the tax authority

(1) Article 45-2(2) of the former Framework Act on National Taxes (amended by Presidential Decree No. 20101, Nov. 27, 2014; Presidential Decree No. 20135, Nov. 27, 2014; Presidential Decree No. 20135, Nov. 27, 2014; Presidential Decree No. 201555, Nov. 27, 2014; Presidential Decree No. 201555, Nov. 27, 2014; Presidential Decree No. 20135, Nov. 27, 2014).