1. The defendant's appeal is dismissed.

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

3. The judgment of the court of first instance is rendered on January 1, 2013.

1. Details of the disposition;

2. The plaintiff's assertion;

3. During judgment

A. The reasoning for the court’s explanation on this part is as follows: (a) add “the Framework Act on National Taxes (amended by Act No. 11873, Jun. 7, 2013)” to “the Act on National Taxes (amended by Act No. 11873, Jun. 7, 2013)”; and (b) add “Article 48(3)” to “Article 18(2)” to “Article 18(2)” under the relevant Acts and subordinate statutes of the court of first instance; and (c) the same applies to the corresponding part of the judgment of the court of first instance.

3. Determination

B. Determination as to the illegality of service by public notice is null and void due to a defect in the requirements for the validity of the disposition (see, e.g., Supreme Court Decisions 82Nu332, May 9, 1984; 95Nu3909, Aug. 22, 1995). The burden of proving whether service by public notice by public notice by public notice by public notice is lawful lies, in principle, at the tax authority (see, e.g., Supreme Court Decisions 94Nu4134, Oct. 14, 1994; 96Nu3562, Jun. 28, 1996). Article 11(1)3 of the Framework Act on National Taxes provides, “Where a person prescribed in Article 10(4) has no place for service by public notice and return it by registered mail, etc., and it is difficult for the recipient to serve documents within the prescribed period for payment by public notice by public notice by public notice by public notice by public official under Article 27-2 of the Framework Act.”