1. The plaintiffs' appeal is dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

Purport of claim and appeal

The first instance court.

1. The reasoning for the court’s explanation concerning this case is as stated in the part of the judgment of the first instance except for the addition of the following contents under Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. In addition, the Plaintiffs asserted that the notification of the results of the reinvestigation made by the Tax Tribunal is not a legitimate notification by the director of the tax office other than the Defendants, the disposition agency. However, whether to take charge of the decision of the Tax Tribunal's reinvestigations and the notification of the results of reinvestigations and reinspections is merely an internal role sharing among the tax authorities within the National Tax Service with respect to the allocation or delegation of authority among the tax authorities, and its external effect does not change accordingly. Furthermore, each notification of the results sent by the director of the tax office in South Incheon District Tax Office to the Plaintiffs is specified by the Tax Tribunal, and the results of reinvestigations on the taxable year, tax items, tax bases, and amount of taxes ("0 amount reduced" and other measures" are stated as the result of reinvestigations ("the initial disposition party"), and the notification is subsequent disposition in accordance with the decision of the appeal, and thus, it can file for administrative litigation

“As long as the content of the method of appeal is specified (as stated in Section 6-1, 2, and 3) and the notice of the result of reinvestigation is lawful, the prior plaintiff’s above assertion is without merit on a different premise.

3. In conclusion, the plaintiffs' claims are dismissed, and the judgment of the court of first instance with the same conclusion is justified, and the plaintiffs' appeal is dismissed as it is without merit. It is so decided as per Disposition.