Which body must an examination request be routed through, and, when the examination-request period is computed, what does the provision treat as the date the request was made?
General information · Not legal advice
Material to check
In a practice file we read the certified copy of the disposition, which names the tax office head who made or should have made it, and the examination request paper itself with the date stamp or receipt showing which office received it first.
These are types of material to look for, not evidence already verified by PRO SE.
Where readings differ
One reading places the examination request with the Commissioner of the National Tax Service, routed through the tax office head who made the disposition or should have made it, with grounds of dissatisfaction set out as the Presidential Decree requires, and treats the request as made, for computing the examination-request period, on the day the paper was submitted to that tax office head.
Another reading notes the wider reach of the filing-date rule: the same also applies when the paper was submitted to a different tax office head, a regional director of national tax, or the Commissioner, so a misdirected filing is treated as made at that moment when the examination-request period is computed, though the provision does not say how the paper then travels to the office named in the first paragraph.
Your judgment
Where the file does not show which tax office head made the disposition, what would establish the correct route and the date from which the period runs?
PRO SE does not make this decision or keep a case record on this public site.When to reconsider
We look at this again if the provision is amended to change the office an examination request must pass through, or the recipients whose receipt counts as the date of filing, or if a decision explains how a misdirected request is forwarded.