On January 5, 2012, the Defendant’s value-added tax of KRW 171,543,200 (including additional tax) imposed on Plaintiff A Co., Ltd. on 2010.

A. Plaintiff A Co., Ltd. (hereinafter “Plaintiff”) is a company engaging in food manufacturing and selling business, and Plaintiff B is an internal director of the Plaintiff Company.

B. The director of the North Mine District Tax Office conducted a value-added tax investigation on the Plaintiff Company.

In 2010 to 1st year 201, the director of the regional tax office of the Gwangju District District Office discovered that “The sales of KRW 1,397,00,000 were omitted through the borrowed account of Plaintiff B, the births of Plaintiff B, and notified the Defendant of taxation data.”

C. (1) Accordingly, on January 5, 2012, the Defendant notified the Plaintiff Company of the correction of the value-added tax of KRW 171,543,200 (including the additional tax), the value-added tax of KRW 64,253,250 (including the additional tax), and the corporate tax of KRW 258,561,960 (including the additional tax) for the business year 2010.

(2) Meanwhile, the Plaintiff Company reported and paid the value-added tax of KRW 8,398,049 for two years in 201.

Accordingly, on March 8, 2012, the Defendant imposed and collected 8,501,340 won by adding 103,296 won to the Plaintiff Company’s non-payment penalty tax.

(3) The Defendant determined Plaintiff B as the oligopolistic shareholder (80%) of the Plaintiff Company, and on February 2, 2012, pursuant to Article 39 subparag. 2 of the Framework Act on National Taxes, designated Plaintiff B as the secondary taxpayer for the amount of delinquent tax [including the amount of additional tax), KRW 171,543,200 (including the amount of additional tax), KRW 64,253,250 (including the amount of additional tax), and KRW 258,561,960 (including the amount of additional tax) for the year 2010 and notified the payment of the amount of delinquent tax.

Since then, the Defendant confirmed that the shares of Plaintiff B decreased to 48% on May 3, 2011, and revoked the designation of the secondary taxpayer on April 3, 2012, the Defendant, on April 3, 2012, designated Plaintiff B as the secondary taxpayer for the amount of non-value-added tax delinquent at KRW 180,806,510 (including additional dues), and the amount of corporate tax delinquent at KRW 272,55,910 (including additional dues) for the business year 2010, and notified the payment of the amount of tax delinquent at issue.

The imposition of value-added tax for the second period of 2010, the first period of 2011, the second period of 201, the corporate tax for the business year of 2010.