1. All appeals filed by the plaintiff and the defendant are dismissed.

2. The costs of appeal shall be borne by each party.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance, such as accepting the judgment of the court of first instance, is as stated in the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as stated in the following (3). As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. On the 9th 19th 2th 19th 6th 6th 19th 19th 200, in a case where a tax authority’s all investigation conducted to collect taxation data or to verify the accuracy of the details of a report constitutes a tax investigation prohibited by re-audit, the tax authority’s mere fact-finding alone does not always commence a regular tax investigation, and it does not constitute a “tax investigation” in which re-audit is prohibited even if the taxpayer, etc. has no duty to answer or accept, and the taxpayer, etc. has no possibility of infringing on the taxpayer’s freedom of business or having no possibility

Whether an investigation conducted by a tax official constitutes “tax investigation” prohibited by re-audit shall be determined individually in a specific case by comprehensively taking into account the purpose and details of the investigation, the object and method of the investigation, the materials acquired through the investigation, the scale and period of the investigation, etc. In principle, it shall be deemed that the investigation conducted by a tax official constitutes mere fact-finding or simple investigation incidental thereto, such as confirmation of the current status of a place of business, simple confirmation of bookkeeping, confirmation of specific sales, issuance of administrative civil petition documents, receipt of data voluntarily submitted by the taxpayer, etc., and thus, it shall be deemed that a taxpayer, etc. can easily respond to such investigation, or that there is no significant impact on the taxpayer