1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. On July 25, 2011, Nonparty B, the Plaintiff’s father (hereinafter “the deceased”), died, and the Plaintiff completed the inheritance tax return following the deceased’s death on January 27, 2012.

B. On August 1, 2013, the Defendant corrected and notified the Plaintiff of KRW 4,030,380, gift tax on September 28, 2008; KRW 5,523,380, gift tax on September 28, 2009; KRW 7,578,360, gift tax on September 28, 2010; KRW 9,752,90, gift tax on July 28, 201; and KRW 33,065,30, respectively.

(hereinafter “instant disposition”). C.

On September 2, 2013, the Plaintiff paid all the amount of tax according to the instant disposition to the Defendant, but filed a claim for correction to the effect that the full refund of the amount was requested on December 29, 2014, but the Defendant rejected the claim on April 14, 2015.

(hereinafter “instant refusal disposition”) D.

On July 9, 2015, the Plaintiff filed a request with the Tax Tribunal for a trial on July 9, 2015, but received a decision of dismissal on September 30, 2015, and filed the instant lawsuit on December 28, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 5, Gap evidence 6-1, 2, Gap evidence 7, Eul evidence 1 through 5, the purport of the whole pleadings

2. According to the above facts finding as to the defense of this case, the Plaintiff was aware of the disposition of this case at least around September 2, 2013. However, since the Plaintiff did not undergo the appeal procedure or file a revocation lawsuit pursuant to the Framework Act on National Taxes within 90 days thereafter, the instant lawsuit is unlawful as it has already been filed after the period for filing the lawsuit expired.

(3) If the Plaintiff’s claim was modified after the closing of argument in the instant case, the Plaintiff sought revocation of the instant corrective rejection disposition, but it is difficult to deem that all requirements, such as the grounds for filing a request for correction, the period for filing a request for correction, and the period for filing a lawsuit, are satisfied.