The initial date in reckoning the period for request for national tax review, if a new tax payment notice has been issued for the collection of the initial tax payment notice and the different

If corporate tax is imposed upon collecting the initial tax payment notice and issuing a new tax payment notice different from the initial tax payment notice, it shall be reasonable to deem that the initial tax payment notice has been withdrawn and a new tax payment notice has been issued. Thus, the request period for review of the imposition disposition shall be calculated on the basis of the date on which a new tax payment notice has been issued.

Article 61 of the Framework Act on National Taxes and Article 9 of the National Tax Collection Act

Attorney Park Chang-chul et al., Counsel for the defendant-appellant

The director of the tax office.

Seoul High Court Decision 81Gu458 delivered on July 8, 1982

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined.

As determined by the court below, if the defendant served a tax payment notice as of September 2, 1980 on September 6, 1980 on the original tax payment notice as of September 15, 1980 on the original tax payment notice for the plaintiff as of September 2, 1980 on the original tax payment notice for the plaintiff, and served a new tax payment notice for September 8, 1980 on September 20, 1980 on the original tax payment notice as of September 20, 1980 on the original tax payment notice to the plaintiff, the defendant withdrawn from September 6, 1980 and issued a new tax payment notice for the first tax payment notice to the plaintiff as of September 20, 1980 on September 8, 1980. Therefore, the court below's determination that the period for filing a request for review is just and there is no error in the misapprehension of legal principles as to the calculation of the period for filing a request for a new tax payment notice

According to the reasoning of the judgment of the court below, the court below recognized the fact that the plaintiff entered into a lease agreement between the non-party's 1978 and the non-party's 8th floor, the 484th floor, the 120,000,000, the deposit money for lease, and the monthly rent of KRW 120,00,000, and the period of KRW 6,000,000, and the above non-party's lease deposit was paid from the above non-party after it entered into the lease agreement with the above non-party for the lease for two years. The court below was just in light of the records of the evidence preparation which was conducted in the above fact-finding, and there was no error of

Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.

Justices Jeong Tae-tae (Presiding Justice)