1. The part of the judgment of the court of first instance against the plaintiff falling under any of the following subparagraphs shall be revoked:

The defendant on September 2016.

1. As to the details of the disposition, the relevant part of the reasoning of the first instance judgment shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion (i) is the first claim for correction under Article 45-2(2)1 of the Framework Act on National Taxes, which provides that “any transaction or act, etc., which forms the basis for calculating the duty base and the amount of duty in the first declaration, determination or correction, becomes final and conclusive as different by a judgment in the relevant lawsuit,” and the “judgment” in this context includes a criminal judgment, and thus, the instant disposition that the Plaintiff rejected the claim for correction based on the instant criminal judgment is unlawful.

In addition, on the ground that the Plaintiff received income deduction through a donation receipt issued by the Plaintiff and the said donation receipt was issued falsely, some of the wage income earners subject to the disposition to revise global income tax were subject to the disposition to voluntarily institute an administrative litigation or revoke the disposition to revise the global income tax based on the instant criminal judgment.

The Defendant alleged the conjunctive claim that he had received a false donation receipt from the Plaintiff, thus making a correction of global income tax. However, the Plaintiff was rendered a judgment of not guilty in the criminal judgment of this case. The correction disposition is an invalid disposition that was made without the grounds of the disposition.

(b) Attached Form 2 of the relevant statutes;

C. (i) The purport of Article 45-2(2) of the Framework Act on National Taxes to determine the primary claim is to expand the relief of taxpayers’ rights by allowing taxpayers to prove the fact when there is a change in the basis of calculation of the tax base and the amount of tax due to the occurrence of a certain subsequent cause after the establishment of the tax liability. Of the grounds for filing a subsequent claim for correction, the law is applicable.