2. The costs of lawsuit shall be borne by the Plaintiff.

Cheong-gu Office

With respect to the Plaintiff, the imposition of value-added tax of KRW 88,087,90 for the first term of 2009, KRW 150,90 for the second term of 2009, KRW 43,216, KRW 110 for the second term of 2010, KRW 148,934,670 for the second term of 2010, KRW 98,38,381, KRW 430 for the first term of 2011, KRW 70,546,850 for the second term of 2011, and the imposition of value-added tax of KRW 80,50 for the second term of 209, KRW 240 for the second term of 209, KRW 216, KRW 110 for the second term of 20, KRW 301 for the second term of 205, KRW 301 for the second term of 205.

A. Articles 17 TL-ro 17 TT-ro Y-gu Seoul JJgu LL-ro 120 of the third floor

After conducting a tax investigation on the above "SH 1" (hereinafter referred to as "the above business entity of this case"), the actual business entity of this case shall be deemed to be the plaintiff, who is the birth of SS, not the right holder of the business, and the plaintiff, who is the birth of SS. The plaintiff supplied the products manufactured by the Chinese DSSH Corporation (hereinafter referred to as "China") to the business entity through the place of business of this case, and received the price through the borrowed account. The tax investigation of the above 380,270,100,000,000,000,000,000 for the above 205,000,000,000,000,000,000 for the remaining 20,000,000,000,000,000,000 won for the last 1, 209, 208, 201,71,06,010,010.

B. On December 18, 2014, the Plaintiff dissatisfied with each of the instant dispositions, filed an appeal with the Tax Tribunal, but the Tax Tribunal dismissed the Plaintiff’s appeal on April 16, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1-1 to 6, Gap evidence 2-1 to 3, Gap evidence 3, Eul evidence 2, the purport of whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The plaintiff's assertion

The instant business entity is a separate business entity separate from the Plaintiff’s Chinese DSSH, and the clothes supplied by China were operated as a trade structure in which the funds were settled in China when the clothing was sold. Expenses incurred in the operation of the instant business entity were borne by Y, and profits arising from the operation of the instant business entity were reverted to Y. Accordingly, since the actual business entity that operated the instant business entity is not the Plaintiff but Y, each of the instant dispositions against the Plaintiff was unlawful on a different premise.

B. Determination

The burden of proving the existence of a tax-exempt fact is against the tax authority, but if the facts presumed to have been proved in light of the empirical rule are revealed in the course of litigation, it cannot be deemed an illegal disposition that failed to meet the taxation requirement against the tax-exempt disposition unless it proves such circumstances (see, e.g., Supreme Court Decision 89Nu6006, Apr. 27, 1990).

① Around May 2002, the Plaintiff established the Chinese DESH before it sets up a Dop, China, etc., and exported the clothing products to Korea, Japan, etc. ② around March 2006, the Plaintiff established and operated the clothing retail business under the trade name, “SHFD” in the Dop, 356, Daz., and closed the business on May 31, 2008; ③ the head of the Hayang District Tax Office did not conduct a tax investigation on the SHFD and corrected the Plaintiff to the Plaintiff on January 22, 2013; ④ the Plaintiff loaned the name of Y or the name of Y from December 2, 2007 to 30, 2007 to 10, 200, 30, 20, 20, 20, 30, 30, 20, 30, 30, 20, 20, 30, 30, 25, 3, 1.

6) If the Plaintiff’s agreement on the operation of the Plaintiff’s store No. 6, 7, Y2, 15-4, 3, 7-1, 7-2, and 8-1, 8-4, the Plaintiff’s explanation that the agreement was made to operate the Plaintiff’s account, and the Plaintiff’s explanation that the agreement was made to operate the Plaintiff’s account was made in the name of the Plaintiff’s account, i.e., the Plaintiff’s business owner’s title and 4, and the Plaintiff’s explanation that the agreement was made in the name of the Plaintiff’s account, i.e., the Plaintiff’s business owner’s title and 4, the Plaintiff’s explanation that the agreement was made in the name of the Plaintiff’s account, and that the Plaintiff’s explanation was made in the name of the Plaintiff’s account owner and the Plaintiff’s statement that the agreement was made in the name of the Plaintiff’s account owner, i.e., the Plaintiff’s statement that it was made in the Plaintiff’s account.

As to this, the Plaintiff asserted that YY is an actual business operator of the instant company on the grounds of various circumstances, including the fact that Y directly decided on the working order and the method of paying the sales price of the instant company, YY’s employee benefits, store management expenses, and rents, and that Y was not paid by the Plaintiff, and that Y was not paid by the Plaintiff, and that DRH prepared accounts of credit on the instant company, but it is difficult to recognize that Y is not an actual business operator of the instant company on the sole basis of such circumstances. In full view of the purport of the entire arguments, it appears that Y was difficult to recognize that Y was not an actual business operator of the instant company. Rather, it appears that Y was delegated by the Plaintiff with the authority to operate the instant company and managed the instant company under the direction of the Plaintiff. Therefore, the Plaintiff’s above assertion is difficult to accept.

Therefore, it cannot be deemed that there was any error in each disposition of this case, in which the Defendants reported the actual business operator of the instant company as the Plaintiff.

3. Conclusion

Therefore, the plaintiff's claim against the defendants of this case is dismissed in its entirety as it is without merit. It is so decided as per Disposition.