1. All appeals filed by the plaintiff and the defendant are dismissed.

2. The costs of appeal shall be borne by each party.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance is determined in paragraph (2) below as to the plaintiff's additional arguments in this court. The fact-finding and decision of the court of first instance are justifiable in light of the plaintiff and the defendant's addition of the additional evidences in this court, and the decision of the court of first instance is just, and there is no error as pointed out by

Therefore, it shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Judgment on the Plaintiff’s additional assertion

A. 1) Whether the Plaintiff’s assertion is a “resident” is difficult to view that the Plaintiff’s domestic residence during the instant taxable period is recognized in view of the Plaintiff’s domestic residence period, close relatives, and vocational relationship. Even if the Plaintiff is a domestic resident, the Plaintiff constitutes a Chinese resident and the Plaintiff’s taxation right in China, which is the center of the Plaintiff’s significant interest pursuant to the Korea-China Tax Treaty, takes precedence over the Plaintiff’s imposition of tax. Therefore, the instant disposition based on the premise that the right to impose tax on the Plaintiff is illegal. (A) Determination on whether the Plaintiff constitutes a “resident” under the Income Tax Act (i) the relevant legal doctrine was amended by Act No. 12852, Dec. 23, 2014; and

According to Article 1-2(1)1 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26067, Feb. 3, 2015), the term “resident” means an individual who has either a domicile in the Republic of Korea or a domicile in the Republic of Korea for at least one year. According to Article 2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26067, Feb. 3, 2015), the address under Article 1-2 of the former Income Tax Act is determined based on objective facts of his/her living relationship, such as the existence of a family living together in Korea and of assets located in Korea (Article 1-1 of the same Act,