2. Whether the instant disposition is lawful

A. The plaintiff's assertion 1) The plaintiff was formally appointed as the joint representative director B for the purpose of securing Eul's claim, and was not involved in the business or operation of B, and was not entirely involved in the process of selling and selling shares in the land of this case, and thus no comprehensive income tax shall be imposed on the plaintiff. In addition, B was paid KRW 2,830,000 out of the transfer price of the land of this case before the plaintiff was appointed as a joint representative director. Since the plaintiff was appointed as a joint representative director, B's disposition which was not paid between June 1, 2009 and April 12, 2010, the remaining transfer price of this case 3,695,950,000 (transfer price of this case 6,525,950,900 won - 2,830,000,000 won - - 309,005,209, 2009,309, 2005.

B. The reasoning for the court’s explanation on this part is the same as that of the corresponding part of the judgment of the court of first instance, and thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

C. 1) Determination on the first argument is based on the following: (a) recognition of the representative under Article 106(1) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 12, 2016; hereinafter the same).