The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

The legality of a disposition is determined depending on whether it exceeds a legitimate amount of tax. The parties concerned may submit objective tax bases and materials supporting the amount of tax until the closing of arguments in the fact-finding proceedings, and when a legitimate amount of tax to be imposed is calculated based on such materials, only the portion exceeding the legitimate amount of tax shall be revoked. However, if not, the entire amount of the taxation disposition shall be revoked, and in such a case, the court shall not be obliged to calculate the legitimate amount of tax to be imposed actively

In light of the records, the court below’s revocation of the entire disposition of this case on the ground of its stated reasoning is just in accordance with the legal principles as seen earlier, and there is no error in the misapprehension of legal principles as to the scope of revocation of the disposition of this case, contrary to what is alleged in the grounds of appeal.

Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices on the bench.