in the case that a special taxable person is converted to a general taxable person, the need for the notice of conversion of tax type.

Where a taxpayer who is a general taxable person under the proviso of Article 25(1) of the Value-Added Tax Act concurrently operates a business that is a business subject to general taxation without reporting a closure of the previous business, it is naturally converted from the taxable period following the commencement of concurrent business to a general taxable person pursuant to Article 74-2(3) of the Enforcement Decree of the Value-Added Tax Act, so the tax office

Article 25 (1) of the Value-Added Tax Act, Article 74-2 of the Enforcement Decree thereof

Handys

Head of Sungbuk Tax Office

(1) The plaintiff's claim is dismissed.

(2) Litigation costs are assessed against the Plaintiff.

On June 15, 1981, the Defendant revoked the disposition of imposition of value-added tax of 2,427,480 won for electricity in 1980 and value-added tax of 272,80 won for subsequent years in 1980 against the Plaintiff.

Litigation costs shall be borne by the defendant.

If the Plaintiff, from around 1976 to around October 1979, paid a tax amount of 90,00 won under the Value-Added Tax Act (the same Chapter 7) and operated a bicycle manufacturing business for children, which is a general taxable person under the same Act (Articles 4 through 6) as well as a general taxable person under the same Act (the same Chapter 4 to the same Act), and as the return and payment of value-added tax for the last half and the last half of 1980, the above special taxable person still runs the above retail business, and the above sales amount of 4,50,000 among them are actually 20,80,60,000 won, and the above tax amount of 20,000,000 won was deducted from each of the above tax amount of 16,80,000 won after deducting the above tax amount of 20,000 won after deducting the above tax amount of 2,000,000 won after deducting the above tax amount of 20,016,00,06,0000 won for each of the Plaintiff's.

First, the plaintiff's assertion that the above provision of Article 25 (1) 4 of the Value-Added Tax Act applies to a manufacturing business operator who runs the above business on June 15, 1981, and that the above provision of Article 25 (4) of the same Act does not apply to the sales business operator who runs the above business on the condition that the above provision of Article 28 (1) 4 of the same Act does not apply to the above provision of Article 7 of the same Act for the first and second taxable period. Since the above provision of Article 25 (4) of the same Act does not apply to the sales business operator who runs the above business on the condition that the above provision of Article 14 of the same Act does not apply to the first taxable period for the second taxable period for the second taxable period for the second taxable period for the second taxable period for the second taxable period for the second taxable period for the second taxable period, the plaintiff's assertion that the above provision of Article 25 (1) of the same Act does not apply to the first taxable period for the second taxable period for the second taxable period for the second taxable period for the second taxable period for the same Article.

Then, the plaintiff notified the plaintiff on June 10, 1981 that the type of tax should be converted to a general taxable person from July 1, 1981. Since the plaintiff's notification was made on June 15, 1981, the plaintiff considered the plaintiff as a general taxable person from January 1, 1980, and the tax disposition of this case was made retroactively to the plaintiff's practice of national tax administration, which had not been applied before the time of the tax disposition of this case, since the plaintiff's notification was made on June 1, 1981, the plaintiff's request for the tax disposition of this case was rejected, and the plaintiff's notification of the tax conversion to the above general taxable person from June 1, 1981 was not a legitimate disposition of this case. Thus, the plaintiff's notification of tax conversion to the above general taxable person is not a legitimate disposition of tax conversion to the above general taxable person under Article 7 (2) 1 of the Enforcement Decree of the same Act. Thus, the plaintiff's notification of tax conversion to the above type of tax disposition of this case is not a general taxable person.

Judges Kim Jong-Un (Presiding Judge) and Kim Jong-sung