1. The judgment of the first instance court, including a claim for addition and modification at the trial court, shall be modified as follows:

In this case.

1. The reasons why the court has used this part of the reasons for the decision of the court of first instance are as stated in Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, except where part of the reasons for the decision of the court of first instance is used as follows. Thus, this part of the reasons for the decision of the court of first instance

[Supplementary part] On April 7, 2014, the second part of the judgment of the court of first instance (hereinafter “instant tax investigation decision”) No. 2, 4 of the second part of the judgment of the court of first instance (hereinafter “the first part”) provides a notice to the effect that “from April 7, 2014, the Plaintiff shall be selected as the subject and that the tax investigation should be conducted against the Plaintiff on April 7, 2014 (hereinafter

The second sentence of the first instance judgment " July 15, 2014" shall be deemed " July 17, 2014."

In the second sentence of the judgment of the court of first instance, the part concerning “a decision and notice” in the 17th sentence is understood as “a decision and notice (hereinafter above 12,332,070 won)” and “a disposition imposing global income tax of KRW 12,332,070 was rendered prior to the instant change.”

Part III through four shall be deleted from the first instance judgment.

2. Determination on the legitimacy of the instant lawsuit

A. The Defendant’s main defense and its determination 1) In a case where a taxation disposition is issued after the completion of an investigation in accordance with the Defendant’s main defense of safety and the Defendant’s main defense (A) based on the tax investigation decision, the pertinent taxation disposition should be deemed as the subject of an appeal litigation, and it is unlawful to file an appeal against the tax investigation

Since the Plaintiff was imposed global income tax in 2012 after the investigation pursuant to the instant tax investigation decision was completed, the part seeking confirmation of invalidity of the instant tax investigation decision among the instant lawsuit is unlawful as there is no benefit of lawsuit.

B. On February 23, 2015, the Tax Tribunal rendered a decision of accepting part of the plaintiff's request for judgment, and the above decision was served on the plaintiff at that time and became effective.

Therefore, 90 days after the date of service of the above decision.