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 reasoning of the judgment by the court of first instance is to delete the part of “from the establishment of the Plaintiff to March 2, 201” in the first instance judgment No. 18 and 19, and the reasoning of the judgment by the court of first instance is to be cited inasmuch as the reasoning of the judgment by the Plaintiff is identical to that of the judgment by the court of first instance, except for addition of the judgment on the Plaintiff’s assertion at the appellate court as described in the following:

2. Judgment on the plaintiff's assertion

A. The Plaintiff asserts to the purport that the Supreme Court en banc Decision 2014Du5514 Decided July 16, 2015, stating that “In the event that the possibility of loss of economic benefits was realized due to the occurrence of a subsequent event where the possibility of loss of economic benefits became final and conclusive as the income is not realized, a taxpayer may, barring any special circumstance, be exempted from the liability to pay the tax by filing a subsequent request for correction stipulated in Article 45-2(2) of the Framework Act on National Taxes, by analogying the legal doctrine that “In the event that the tax liability initially established comes to be lost due to the occurrence of a subsequent event where the possibility of loss of economic benefits

B. However, considering the following circumstances, the above legal doctrine cannot be applied by analogy to the instant case. Therefore, the Plaintiff’s assertion on this part is without merit.

1. The judgment cited by the Plaintiff is a matter of issue as to whether to impose global income tax on the “individual” under the Income Tax Act, and the purpose of confiscation or collection in the crimes, such as bribe, good offices, and breach of trust, under the Criminal Act is to deprive the benefits from the criminal act and prevent the illegal gain from being held. Thus, if confiscation or collection was made for such unlawful income, it constitutes a real case where the possibility of loss of economic benefits inherent in the illegal income is realized, and in such a case, the said income is not ultimately realized.