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 reasons for the court's explanation concerning this case are as follows: (a) deletion of the part of the 6th judgment of the court of first instance No. 8; (b) removal of the part of the 6th judgment of the court of first instance No. 27-2; (c) “Article 27-2” as “Article 27; and (d) “No. 5 and” after the 9th judgment of the court of first instance are as stated in the grounds for the 1st judgment, except for addition of the following in the 1st judgment of the same section; and (d) this reference is as stated in the grounds for the 1st judgment.

2. Article 47-3(2) of the former Framework Act on National Taxes provides that an amount equivalent to 40/100 of the amount calculated by multiplying the ratio of the underreportedly underreported tax base to the tax base by the calculated tax amount shall be either added to the payable tax amount or deducted from the refundable tax amount. Article 47-2(2) of the former Framework Act on National Taxes defines the meaning of “unfair method” as “any method prescribed by Presidential Decree, in which a taxpayer violates the duty to report the tax base or tax amount of national tax on the basis of concealing or pretending all or part of the fact that serves as the basis for calculating the tax base or tax amount of national tax,” and Article 27(2) of the former Enforcement Decree of the Framework Act on National Taxes (amended by Presidential Decree No. 23592, Feb. 2, 2012; hereinafter the same shall apply) upon delegation refers to any of the following methods:

3. The decision of the first instance court is legitimate, and the plaintiff's appeal is without merit.