Busan High Court-2015-Nu-20916 ( October 12, 2015)

(A) Notice of attachment is only subject to the notification of concept, but is not subject to appeal litigation.

(The main point of the judgment below) The attachment notice merely notifies the plaintiff's deposit claim, benefit claim, etc. that if the tax in arrears is not paid within a certain period of time is expected to be seized, it cannot be deemed that it directly affects the rights, obligations or legal status, and thus, it cannot be deemed an administrative disposition that is subject to an appeal litigation.

Article 23 of the National Tax Collection Act: Demand and peremptory notice

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the judgment below and the appellate brief examined the records of this case, but the appellant's grounds of appeal are not included in the grounds provided by each subparagraph of Article 4 (1) of the Act on Special Cases Concerning the Procedure of Appeal, or are recognized to be groundless. Thus, the appeal is dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by the assent of