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. The reasons why the court should explain this case are as stated in the reasoning of the judgment of the court of first instance other than the following. Thus, this case is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

The 8th parallel 4 to 14th parallels are as follows.

【B) A tax investigation is a kind of administrative investigation to realize the State’s right to impose taxes, and refers to any act of making inquiries to determine or correct the tax base and amount of national taxes and inspecting or investigating account books, documents and other articles or ordering the submission thereof. In the case of a tax investigation for which the authority to inquire and investigate by the tax authorities for imposition is exercised, the taxpayer or any person, etc. who is deemed to have a transaction with the taxpayer (hereinafter “taxpayer, etc.”) bears the legal obligation to answer questions for tax officials to collect the tax data and to allow the investigation.

On the other hand, it is necessary to prohibit double tax investigations for the same items of taxation and the taxable period, except in exceptional cases where it is clearly contrary to the principle of fair taxation, since the freedom of taxpayer's business and legal stability may be seriously infringed as well as the abuse of the right of tax investigation.

In light of the nature and effect of such tax investigation, the purport of prohibiting duplicate tax investigations, etc., where a tax official’s act of investigation substantially affects the taxpayer’s freedom of business by having the taxpayer answer questions and undergo an inspection, etc., it shall be deemed as an “tax investigation” prohibited by re-audit, even if it is in accordance with the procedure of “local confirmation” as stipulated in the former Regulations on the Management of Investigations by the National Tax Service

However, all investigations conducted by tax authorities to verify the accuracy of the collection of taxation data or the details of the report.