The appeal is dismissed.

Costs of appeal shall be borne by the plaintiff.

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

1. As to the first ground for appeal

A. Article 30 of the former Customs Act (amended by Act No. 12027, Aug. 13, 2013; hereinafter the same) provides that the dutiable value of imported goods shall be the transaction price adjusted by adding the amount prescribed in each of the following subparagraphs to the price actually paid or payable by a buyer for the goods sold to be exported to Korea. Article 30 of the former Customs Act provides that the dutiable value of the imported goods shall be the transaction price adjusted by adding the amount prescribed in each of the following subparagraphs, such as commission and brokerage, to the price actually paid or payable by the buyer for the goods sold to Korea. Article 30 of the former Customs Act provides that “Where a special relationship prescribed by Presidential Decree between the buyer and the seller affects the price of the relevant goods, the transaction price prescribed in paragraph (1) shall not be the dutiable value of the relevant goods, and the method

B. In order to apply Article 30(3)4 of the former Customs Act, the lower court: (a) premised on the legal doctrine that a taxation authority should prove that a special relationship between the Plaintiff and the head office of the United States has an impact on the transaction price of each of the instant goods, on the grounds stated in its reasoning; (b) and (c) based on the reasoning of its reasoning, the lower court acknowledged that a special relationship between the Plaintiff and the head office of the United States had an impact on the transaction price of each of the instant goods; and (b) the Defendant did not consider refund

It was determined that the denial of report could not be determined as illegal.

The judgment below

In light of the foregoing provision and relevant legal principles and records, the lower court erred by misapprehending the legal doctrine on the burden of proof or by misapprehending the legal doctrine regarding the burden of proof.