1. The judgment of the court of first instance is modified as follows.

On July 1, 2014, the Defendant reverted to the Plaintiff, 2009.

1. The reasons for the judgment in this part are as follows. The reasons for the judgment in this part are as follows: (a) adding “(Account Number: E Bank F; hereinafter “the instant borrowed account”) to “the instant borrowed account”; (b) the third 15 parallel “ July 9, 2014” to “ July 1, 2014”; and (c) as stated in the corresponding part of the judgment of the first instance; and (d) the same shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the disposition is lawful;

A. The reasoning of the judgment in this part of the Plaintiff’s assertion is as follows, except that the following is added to four pages of the judgment of the court of first instance, and this part of the judgment is identical to the corresponding part of the judgment of the court of first instance.

[Additional Contents] 3) An account under the name of another person for whom the Plaintiff received an operation fee under the name of another person by asserting that it was illegal is limited to only one of the instant borrowed account under the name of D, which was considered by the Plaintiff and the same business, and filing a return by simply omitting the income deposited in the said account cannot be deemed an act of concealing income, and any active act of writing the appearance, such as preparation of false documents, etc. Therefore, the Plaintiff’s act cannot be deemed as constituting “Fraud or other unlawful act.” Therefore, the imposition of penalty tax by underreporting is unlawful. (b) The imposition of penalty tax by underreporting is unlawful. (c) The reasons for the judgment on this part are as indicated in Attachment 2 of the related Acts and subordinate statutes. The reasons for the judgment on this issue are as follows; (84 Du8630, Apr. 1, 198; and (8) 1) 2014Du1360, Jan. 16, 201>