Article 106Succession to the Status of Appellant

①If an appellant dies, the heir (or, where the provisions of Article 951 (Formation of a Corporation of Inherited Property) of the Civil Code apply, the corporation referred to in that Article) succeeds to the status of the appellant.

②If an appellant has undergone a merger or a split (limited to a split that causes the rights connected with the disposition that is the subject of the appeal to be succeeded to), the corporation surviving the merger or the corporation incorporated through the merger, or the corporation that has succeeded to those rights through the split, succeeds to the status of the appellant. The same applies to a corporation that has comprehensively succeeded to the rights and obligations belonging to the property of an association or foundation without legal personality that is an appellant.

③In the cases referred to in the preceding two paragraphs, the person who has succeeded to the status of the appellant must notify the President of the National Tax Tribunal, etc. of that fact in writing. In this case, a document proving the fact of the succession to rights due to death or a split, or of the merger, must be attached to the written notification.

④A person who has acquired by assignment the rights connected with the disposition that is the subject of an appeal may succeed to the status of the appellant with the permission of the President of the National Tax Tribunal, etc.