1. The plaintiff's appeal against the defendants is dismissed in entirety.

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

purport, purport, and.

The reasoning for the court’s explanation of this case is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the judgment of the plaintiff’s new argument in the court of first instance as stated in paragraph (2). Thus, this is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

In the process of investigating tax offenses against F, the public official in charge of the Gwangju Regional Tax Office added the Plaintiff’s argument that the Plaintiff’s tax invoice issued by F was due to a disguised transaction, and the Plaintiff did not comply with the request for submission of the above public official’s data.

Such speech and behavior do not differ from the act of practically depriving of the opportunity to vindicate, and the Defendants were subject to the instant disposition in accordance with the conclusion of the instant investigation. As such, the part relating to F in the instant disposition is unlawful due to procedural defects.

Judgment

In contrast, the investigation process in which the Plaintiff’s deprivation of opportunity to vindicate constitutes F’s tax offense. Even if there were any circumstances in which the Plaintiff’s data was not submitted during that process, as long as the tax investigation was conducted on the Plaintiff thereafter, it can be said that the Plaintiff could have made a vindication of the disguised transaction prior to the instant disposition by claiming a pre-assessment review on the results of the tax investigation conducted by another public official on himself.

Therefore, since the above circumstance alleged by the Plaintiff cannot be deemed to have deprived of the opportunity for prior vindication, the above procedural illegality argument by the Plaintiff is without merit.

3. In conclusion, the judgment of the first instance is legitimate, and all appeals against the Defendants by the Plaintiff are dismissed. It is so decided as per Disposition by the assent of all participating Justices.