1. The plaintiff (appointed party)'s appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff (Appointed Party).

1. The court's explanation concerning this case is based on the reasoning of the judgment of the court of first instance.

The part of “judgment”, which is the appellant, is used as follows, and the reasoning of the judgment of the first instance is the same as the reasoning of the judgment of the first instance, except where the “instant disposition” among the grounds of the judgment of the first instance is deemed as the “each of the instant dispositions,” and such part is cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence

2. (1) As seen earlier, the Plaintiff et al. received a global income tax payment notice on May 16, 2012 and filed an objection on September 24, 2012 after the lapse of 90 days from the receipt of the global income tax payment notice on May 16, 2012. Therefore, it appears that the Plaintiff et al. filed a lawsuit seeking the revocation of the disposition imposing global income tax for the imposition of global income tax for the year 2004 without undergoing the lawful pre-trial procedure.

However, the following facts are acknowledged if Gap evidence 5-3, 19, Eul evidence 22-1 to 8 are added to the purport of the whole pleading:

On April 6, 2012, the Defendant sent a notice of pre-taxation that the deceased will be subject to comprehensive income tax for the year 2004, 2005, 2006, and 2008 and attached the document notifying the procedures for remedy of rights.

Plaintiff

On May 14, 2012, the defendant filed a written objection on the pre-announcement of taxation, and the period for exclusion of global income tax in 2004 until May 31, 2012.

(6) On June 1, 2005, when the exclusion period of global income tax was commenced, a tax payment notice was first issued to the plaintiff et al. on the same day on the same day for the reason that "seven years have elapsed since the exclusion period of imposition due to non-declaration of global income tax)."

On July 3, 2012, the Defendant deemed the Plaintiff’s objection as the request for pre-assessment review and made a non-adopted decision on July 3, 2012, and notified each correction of global income tax of KRW 112,653,840 (including additional tax), global income tax of KRW 31,709,58 (including additional tax) for the year 2005.

Accordingly, the plaintiff et al. on September 24, 2012.