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. Acknowledgement of the reasons for the judgment of the court of first instance is the same as the entry of the reasons for the judgment of the court of first instance, in addition to the portions added below or determined additionally under Paragraph 2, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

Additional Acts and subordinate statutes concerning judgment of the first instance court shall be added in the attached Form of this Court.

2. Additional determination

A. 1) The Plaintiff’s assertion is lawful in the instant disposition. Inasmuch as the Defendant, although there was no ground to select a tax investigation subject under Article 81-6(3) of the Framework Act on National Taxes, did not collect taxation data and imposed tax accordingly, the instant disposition is unlawful. 2) The Plaintiff’s assertion is prior to the amendment by Act No. 8139, Dec. 30, 2006; hereinafter “former Framework Act on National Taxes”).

(2) In light of the legislative purport of Article 81-3(1) and (2) of the former Framework Act on National Taxes (amended by Act No. 1154, Jun. 26, 2014) and Article 81-3(1) of the former Framework Act on National Taxes (amended by Act No. 1154, Nov. 29, 2012; Act No. 11554, Nov. 29, 2012; Act No. 11554, Nov. 29, 2012; Act No. 20144, Jan. 1, 2012; Act No. 20135, Jan. 1, 2012; Act No. 20144, Jan. 1, 2012).