All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. As to the ground of appeal No. 1, Article 30-4 of the former Local Tax Act (wholly amended by Act No. 10221, Mar. 31, 2010; hereinafter the same) provides that the exclusion period of local taxes shall be five years, in principle, as to the grounds of appeal No. 1, Article 30-4 of the former Local Tax Act (wholly amended by Act No. 1021, Mar. 31, 2010; hereinafter the same shall apply). Paragraph (2) provides that “In the event of a request for objection, request for examination, request for examination under the Board of Audit and Inspection Act, or

In light of the language, purport, etc. of these provisions, a taxation authority may only apply the said provision to a taxpayer who has received the said judgment, etc. and whose effect of the taxation disposition that has been revoked or altered by the said judgment, etc., and may not apply the said provision to a third party who does not have the effect of the taxation disposition that has become the object of revocation or alteration, barring special circumstances such as succession of tax liability, etc.

(2) In light of the fact that the establishment of secondary tax liability constitutes a disposition of imposition against the secondary taxpayer by requiring a separate requirement such as the principal taxpayer’s default, etc., in addition to the establishment of the principal tax liability, the imposition against the secondary taxpayer constitutes an independent disposition of imposition against the principal taxpayer, and the effect of the disposition of imposition revoked or modified by the judgment, etc. against the secondary taxpayer does not extend to the principal taxpayer.