The judgment below is reversed and the case is remanded to Seoul High Court.

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

1. Article 8(1) of the Framework Act on National Taxes provides that a place for service of documents under the Framework Act on National Taxes or other tax-related Acts (hereinafter “domicile or place of business”) shall be “where a person under Article 10(4) is unable to serve a document at a place where the document is to be served, and where the document is returned to the absence of the recipient, etc. by registered mail,” and Article 7-2 of the Enforcement Decree of the Framework Act on National Taxes provides that “where it is deemed difficult to serve a document by the due date for payment due to the absence of the recipient,” under Article 11(1)3 of the Act on the grounds of service by public notice.

Considering the language and text of the provision, the purport of the service by public notice under Article 11 of the Framework Act on National Taxes, and the purport of the service by public notice where the document is not served until the document is not served due to any cause not attributable to the taxpayer, which is likely to excessively infringe on the right to a trial under Article 27(1) of the Constitution, a tax authority’s duty to serve by public notice may impose a tax notice pursuant to Article 11(1)3 of the Framework Act on National Taxes, on the grounds that the tax authority is able to serve by public notice, and the tax authority’s duty to serve by public notice refers to the taxpayer’s address or place of business that may be known by conducting an investigation with due care as a good manager, and the taxpayer’s duty to serve at each place may be attempted to serve by public notice at each place.