1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasons for the court’s explanation concerning this case are as follows: “A request for correction is made to the defendant” under Section 21 of the judgment of the court of first instance; “A request for correction is made to the defendant”; and the following Section 2 of the judgment is the same as the part of the reasoning of the judgment of the court of first instance, except for addition of the judgment as to the new argument made by the plaintiff in the court of first instance, it is so accepted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. The addition;

A. The plaintiff's assertion that the plaintiff's claim for correction is legitimate within the period under Article 45-2 (2) 5 of the Framework Act on National Taxes and Article 25-2 (3) and 4 of the Enforcement Decree of the same Act, but the defendant's rejection of the claim for correction due to the expiration of the period constitutes an illegal rejection disposition, and therefore, the plaintiff's claim for correction can be

B. In light of the determination, Article 45-2(2) of the Framework Act on National Taxes provides for an ex post facto request for rectification by providing that “Any person who has filed a return on a tax base by the statutory deadline for filing the return, or who has received the determination of the tax base and amount of national taxes, may file a request for the determination or correction within two months from the date on which he/she becomes aware of the occurrence of the cause, regardless of the period stipulated in

However, in the claim for correction and the claim of this case, the ground for the plaintiff's assertion is that "the plaintiff completed the registration of ownership transfer by donation of grounds for registration, but the facts are not the donation of the real estate of this case, and its acquisition value should be calculated differently." Thus, the plaintiff's request for correction constitutes grounds for subsequent

The claim cannot be deemed to have been filed within 2 months from the date on which the cause occurred, and the claim period shall be deemed to be unlawful in excess of the claim period.

Therefore, it is true.