1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. The Plaintiff, a corporation engaged in wholesale business and trade business, purchased food such as fruit, and exported food to China.

B. From January 20, 2016 to June 10, 2016, the director of the Central Regional Tax Office discovered that the Plaintiff omitted the Plaintiff’s report on the amount of income belonging to the business year 2013 to 714,421,04, and the amount of income belonging to the business year 2014 to 106,458,884, and notified the Defendant of the taxation data.

C. On July 1, 2016, the Defendant notified the Plaintiff of the rectification of KRW 539,574,840 of the corporate tax reverted to the business year 2013, and KRW 63,961,550 of the corporate tax reverted to the business year 2014.

(hereinafter referred to as the "disposition of this case"). [Grounds for recognition] Gap's 1 to 3, Eul's 1 to 5, and the purport of the whole pleadings

2. Determination on the defense prior to the merits

A. The Plaintiff asserted that the instant disposition was served on July 6, 2016, and filed an objection against the instant disposition on October 5, 2016 after the lapse of 90 days from the filing period under the Framework Act on National Taxes. As such, the instant lawsuit is unlawful since it did not go through lawful pre-trial procedures.

B. Where a person is dissatisfied with a disposition imposing national taxes, a lawsuit seeking revocation against the disposition imposing national taxes may be instituted only through a request for a trial, etc., prescribed in Articles 56(2) and 55 of the former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same). In this case, the request for a trial, etc. must be lawful by complying with the request period. As such, in a case where the procedure of the preceding trial, such as a request for a trial, is unlawful due to the lapse of request period, the lawsuit seeking revocation against the disposition imposing national taxes is unlawful

According to Articles 61(1), 61(2), and 68 of the former Framework Act on National Taxes, a request for a trial against the imposition of national taxes shall be made.