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

A. From November 1, 2011 to May 5, 2014, the Plaintiff established and operated a member of the Council (hereinafter “instant member”) under the trade name “D” in Yeonsu-gu Incheon building B and C.

B. As a result of the personal integration investigation conducted between May 24, 2017 and June 12, 2017 with respect to the Plaintiff, the head of the Namcheon District Tax Office included KRW 304,120,934 (251,328,380,380, and 52,792,54) in total income of the Plaintiff from May 24, 2017 to June 12, 2017, and included KRW 51,167,265, in necessary expenses, and notified the Defendant of the result of such investigation that the amount of income accrued in the year 2012 through 2014 (cash sales) was omitted, and the amount of income accrued in the year 2012 and 2014; KRW 304,120,934 (cash sales); and KRW 52,792,548,208, 2081, 2017.

(C) Only the sum of global income tax for the year 2012 and year 2013, on which the Plaintiff argued the illegality of the disposition, KRW 52,322,940 (hereinafter “instant disposition”).

On November 3, 2017, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on November 3, 2017, and on February 14, 2018, the Tax Tribunal rendered a decision to re-examine whether the Plaintiff jointly operated the instant member E and correct the relevant tax base and tax amount, and the Defendant issued a notice of the result of tax investigation on May 31, 2018, to the effect that the initial disposition as a result of re-audit to the Plaintiff is lawful and complete the investigation.

In other words, the Plaintiff again appealed to the Tax Tribunal on August 27, 2018, but the Tax Tribunal dismissed the Plaintiff’s above claim on May 22, 2019.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 3, 9, 11, Eul evidence Nos. 1 and 2 (including each number), the purport of the whole pleadings

2. The instant disposition is lawful.