propriety of any disposition imposed more than the amount of corporate tax base;

Even if the tax authority has errors in the amount of tax calculated more than the tax base, it is merely illegal and thus constitutes grounds for revocation, and it cannot be deemed that the defect is significant and obvious as invalid.

Article 26 of the Framework Act on National Taxes extinction of Payment Liability

Article 27 of the Framework Act on National Taxes

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance court is revoked. In the first instance court, it is confirmed that the defendant's right to collect 27,454,210 won in total of 260,874,590 won in arrears and 260,878,30 won in arrears and 37,247,70 won in arrears and 37,247,70 won in arrears and 6,348,590 won in arrears and 260,874,590 won in total, which the defendant decided and notified as the payment period on July 15, 1981 to the plaintiff, was nonexistent, and it is confirmed that the disposition of imposition is null and void in relation to the amount equivalent to 217,278,300 won in arrears and 37,247,700 won in defense and 6,348,590 won in total, and 260,874,254,210 won in arrears.

The reasoning of the court's explanation concerning this case is the same as that of the judgment of the court of first instance, and thus, it is acceptable to accept this case in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

Therefore, the judgment of the court of first instance is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.