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

This Court's reasoning is the same as the corresponding part of the judgment of the court of first instance. Thus, this Court's reasoning is acceptable in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Whether the dispositions of the instant case are legal.

A. The plaintiff's principal

At the time of transferring the instant business, the Plaintiff, etc. was expected to collect taxes exceeding KRW 600 million from the Plaintiff, etc. regarding the instant business. However, in order to avoid the disposition of arrears on the Plaintiff, etc.’s property, the Plaintiff, etc. merely pretended to comprehensively transfer and discontinue the instant business to the headB, who is the punishment of the Plaintiff, etc., and in fact continued to operate the instant business. As such, the instant disposition based on the premise that the instant business

(b) Related statutes;

It is as shown in the attached Form.

C. Determination

(1) Whether the Plaintiff et al. pretended to transfer the instant business to the headB

Comprehensively taking account of the following various circumstances, it is deemed that the Plaintiff et al. lent its name from the ChapterB to that of the Plaintiff et al. and pretended to transfer the instant business.

① From December 2, 2005 to February 2, 2006, the Central Regional Tax Office conducted an integrated tax investigation into the Plaintiff’s workplace (DB club). As a result of the tax investigation, the Plaintiff et al. was anticipated to be presumed to have been presumed to have received approximately KRW 670 million, such as value-added tax and special consumption tax (the testimony of this Decree). As such, there was a motive to pretend that the Plaintiff et al. transferred the business to avoid tax presumption.

② The comprehensive transfer and acquisition contract (No. 4 and No. 4-2) signed by the Plaintiff et al. between the headB and the headB only affixed the seal of the Plaintiff et al., and the headB, the transferee, did not pay the price of KRW 1.5 billion to the Plaintiff et al. by the end of 2006, which is the due date. The Plaintiff et al. did not urge the headB to pay the price (or each testimony by the headB and Kim Tae-tae). Considering the scale of the instant business and the amount of the transaction, it is very exceptional that the transferor did not urge the payment of the price even if the transferee did not pay the price under the transfer and acquisition contract.

③ The Plaintiff and the head of the Dong prepared to the head of the building to lease the instant building (No. 4,5). Although the Plaintiff and the head of the Dong did not pay KRW 500,000 to the head of the building, the Plaintiff and the head of the Dong did not demand the head of the building to pay the total amount of the lease deposit (the testimony of the headB and Kim Tae-tae). Considering the amount of the lease deposit, it is very unusual that the lessor did not demand the payment even if the lessee did not pay the lease deposit, it is very rare that the lessor did not demand the payment.

④ After entering into a comprehensive transfer and acquisition contract with the head of CCB on February 19, 2006, the bank account of CCB opened on April 14, 2006 with respect to the instant business was registered with the telephone number of the Plaintiff and the telephone number opened in the name of the Plaintiff’s address (Evidence 11) (Evidence 11, 12). Furthermore, after the transfer and acquisition contract, the Plaintiff signed and sealed a large amount of money from the bank’s account with the above CCB’s 2006 1’s 1’s 6’s 2’s 1’s 5’s 1’s 6’s 2’s 1’s 2’s 15’s 1,23,16’s 16’s 12’s 1’s 5’s 1’s 6’s 1’s 6’s 2’s 1’s 2’s 1’s 2’s 2’s 2’s 2’s 2’s 2’s 2’s 2’.

Meanwhile, even between May 2006 and October 2007, 2007, the aboveCC’s transfer account and its direct management account (138-021713-02-202) in Korea’s bank tin village and its branch account (138-02-13-0202) have been traded more than KRW 300 million once (i.e., evidence No. 17, evidence No. 10-1, No. 10-2), but it is difficult to conclude that B had been actually engaged in the instant business solely on the ground that there was such transfer transaction (the testimony by the headB).

⑤ AB made a statement that he/she only lent his/her name, and that he/she did not actually conclude a transfer/acquisition contract (Evidence No. 6-1, 2, 7, and B’s testimony).

6. The Plaintiff et al., upon commencing the instant business, subscribed to fire insurance and digital TV in the Plaintiff’s name, and agreed to transfer the instant business to the headB, and did not change the Plaintiff’s name even after the occurrence of the agreement (Evidence No. 2, 3, and B B).

7) On the other hand, according to Gap evidence Nos. 10, Eul evidence Nos. 10, Eul evidence Nos. 4-1 through 7, Eul evidence Nos. 6, Eul evidence Nos. 7-1, 2, 3, Eul evidence Nos. 9, and Eul evidence Nos. 7-2, witness B, Lee Young-young, and Kim Tae-tae's testimony, the headB directly applied for the registration of the business of this case to Situ-si, and on April 4, 2006, the head applied for the registration of the business of this case with the above comprehensive transfer/acquisition business license certificate and real estate lease contract attached to the above comprehensive transfer/acquisition contract, and on April 11, 206, the defendant investigated the local confirmation of the building of this case on the above application for the registration of business, and the headB at the time presented documents related to land expropriation loan and land expropriation compensation related to the source of the business of this case, and confirmed that he/she was the actual entrepreneur of this case and the rental business of this case No. 206B.

Various circumstances revealed in each of the above facts may serve as the basis for deeming that the Plaintiff, etc. actually transferred the instant business to the headB. However, even if there exist such circumstances, it is not always deemed that the Plaintiff, etc. were the actual transfer of the instant business from the headB to the headB. In order to pretend that the Plaintiff, etc. only lent the name of the headB to the headB and transferred the instant business, the headB directly applied for business permission, made a vindication on the source of the business fund in the on-site verification, made a vindication on the source of the business fund in the on-site verification (the headB made a vindication as land expropriation compensation for the source of the business fund, but it appears that the headB used approximately KRW 1.4 billion as land expropriation compensation for the source of the business fund, and paid the value-added tax for the instant business by deducting the rent from the headB as the input tax amount.

8) In addition, even before the registration of the business of this case was made, the head of B had been engaged in operating the BB’s age club four times from 1991 to 199 (Evidence 6). However, such circumstance alone does not make it difficult for BB to keep its name lending in relation to the instant business. Rather, considering that the headB’s experience along with such experience of the head BB is a type of A, one person among joint business operators, the headB should be deemed to be sufficiently capable of lending its name.

(2) Whether the plaintiff's assertion that the business of this case was removed as it transferred is against the principle of trust and good faith

① The principle of trust and good faith in relation to the law of substantial taxation, which strongly acts under the principle of legality, shall only be applied to cases where it is deemed necessary to protect specific trust even if the principle of trust and good faith is sacrificeed to the principle of trust and good faith. In order for taxpayers to apply the principle of trust and good faith, there is an objectively contradictory behavior, and the behavior was derived from the taxpayer’s severe faith, and the tax authority’s trust resulting therefrom should be protected (see Supreme Court Decision 2006Du14865, Apr. 23, 2009).

② In order to avoid the disposition on default of taxes worth KRW 670,000,000, the Plaintiff et al. entered into a contract with the head and the head and the head and the head and the head and the head and the head and the head and the head and the head and the head have entered into a comprehensive transfer and acquisition of the instant project; on April 12, 2006, the head and the Plaintiff et al. registered their business as to the instant project on April 15, 2006, and filed a final return on the tax base and tax amount of value-added tax for 1, 2006; the Plaintiff et al. entered into each lease agreement with the head and the head and the head and the head and the head and the head were to lease the instant building on March 3, 2006; the Plaintiff and the head and the head and the head and the head and the head have paid taxes, including value-added tax, by registering as the rental business operator and the tax amount for the instant building; the head and the head and the head and the head and the head were the head and the tax were 6.

In light of the above legal principles, such as the Plaintiff’s contradictory speech and behavior and the background leading up to it and the degree of criticism, the nature of the value-added tax base for the first time in 2006, the protection value of the Defendant’s trust, and value-added tax, etc., in principle, the tax authority’s authority to investigate the instant business in the tax return method that the taxpayer voluntarily determines and reports the tax base and tax amount, as well as the secondary and supplementary tax amount, is presumed to have transferred the instant business to BB. In addition, it is reasonable to deem that the Plaintiff et al. was presumed to have presumed to have transferred the instant business, and that the Plaintiff et al. paid the value-added tax on the instant building after completing the business registration under the premise that the building was leased to B after making a report on the closure of the business, and the Defendant’s payment of the value-added tax on the said building did not constitute a comprehensive transfer of the instant business after making

D. Sub-committee

The plaintiff et al. pretended to transfer the business of this case to the headB, but such plaintiff's assertion violates the principle of good faith, so the disposition of this case is legitimate.

3. Conclusion

Therefore, the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed as it is so decided as per Disposition.