1. Revocation of the first instance judgment.

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasons why the court should explain this part of the disposition are the same as the part of the "1. Circumstances of the disposition" stated in the second-third of the judgment of the court of first instance, except for the dismissal or addition as follows. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

Under the two pages, the "tax on global income for the 2010-2012" in the 6th line is "tax on global income for the 2009-2012."

Under 2, the "additional Tax for Illegal Inreporting" for 3 and 3 others are respectively referred to as "additional Tax for Illegal Inreporting".

2 Under the two pages, the term “tax on global income (including additional tax; hereinafter the same shall apply) for the year 2010” is “tax on global income (including additional tax; hereinafter the same shall apply) for the year 2009, 115,965,530 won, and global income tax for the year 2010.”

The 3rd two parallels " April 8, 2016" shall be deemed " March 18, 2016".

3. On the right side of "for the plaintiff," adding "a decision of correction to revoke the comprehensive income tax belonging to year 2009 on the ground of the expiration of the exclusion period," "for the plaintiff."

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1) Since the illegal tax investigation of the gift tax of this case was unlawful as follows, the disposition of this case based on the taxation data collected through the illegal tax investigation of the gift tax of this case is unlawful. A) The Plaintiff did not have received property donation from others from 2009 to 2012, which is the taxable period subject to the investigation of the gift tax of this case.

Nevertheless, the director of the Central Regional Tax Office of China conducted a tax investigation of the gift tax of this case only with a vague trend that the shortage of the plaintiff's financing source reaches KRW 1.32 billion compared to the acquisition of the plaintiff's property, such as the plaintiff's real estate.

Therefore, in the instant gift tax investigation, Article 81-6(4) of the former Framework Act on National Taxes (amended by Act No. 13552, Dec. 15, 2015; hereinafter the same) and the former Inheritance Tax and Gift Tax Act (amended by Act No. 1190, Jan. 1, 2013).