1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance cited by the court of first instance is as follows. The reasoning of the judgment is as follows, with the exception of adding a judgment on the argument that the defendant newly raised in this court pursuant to Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, citing the reasoning of the judgment of the court of first instance as follows.

Two pages "831,66,396 won" shall be deemed "831,686,396 won" of 10 pages.

The 3rd page "(3)" was added to "the designation of a joint and several taxpayer against the Plaintiff" (hereinafter referred to as "the instant disposition").

3. The following shall be added to the three parallels following:

E. The Plaintiff dissatisfied with the instant disposition and filed a request with the Tax Tribunal for the trial on March 24, 2016, but was dismissed on July 13, 2016. The Plaintiff’s “Evidence 5 and 6” in the 4th page 14 of the instant disposition is deemed to be “Evidence 3-6.”

4 Myeon 14-15 "This Court" is referred to as "the first instance court and this court".

4. The term "cash" in the 19th page shall be read as "cash and check".

2. Judgment on the defendant's additional assertion

A. Even if the Defendant’s assertion that the issue amount cannot be seen as a prior donation by the decedent to C, the Defendant could use and benefit from the money deposited in the account in the name of C by controlling and managing the deposit account in the name of C, and thus, the Defendant may be deemed to have made a prior donation to the network D rather than C.

Therefore, from this point of view, the instant disposition against the Plaintiff is legitimate.

(B) The defendant added the above reasons in the first instance. (B)

Since the subject matter of the taxation disposition suit concerning preliminary disposition is objective existence of the tax amount determined by the tax authority, the tax authority's legitimacy of the tax base or tax amount recognized in the pertinent disposition by the time of closing argument in the fact-finding proceedings.