The remaining portion of the money deposited in the borrowed account left after the Defendant reduced as above shall be the amount omitted by the Plaintiff.

It can be presumed that the plaintiff's above part is not the omission amount of sales.

It is necessary to prove that it is.

B) Meanwhile, the record of the evidence submitted by the Plaintiff was based on the duly examined evidence as seen earlier.

(1) The amount deposited in the Plaintiff’s corporate account in 2002 is an OO and a borrowed account.

The amount deposited is a total of OO, and the plaintiff is a total of OO (=OO)

by issuing tax invoices equivalent to the amount of KRW 100 in the year 2002, more than KRW 1000.

(2) The amount deposited into the Plaintiff’s corporate account in 2003 shall be the total of the OO members.

J. The amount deposited into the borrowed account is a total of OO, which is the sum of the plaintiff's OO.

A tax invoice equivalent to more than KRW 100,000,000 than KRW 10,000.

(3) The amount deposited into the Plaintiff’s corporate account in 2007.

The amount deposited in the name account is a total of OO members, and the plaintiff is a total of OO members.

OO(=OO's + O's) more than the aggregate amount of OO

It is recognized that a sales report was filed in 2007 by issuing a tax invoice equivalent to the original tax invoice.

C) However, the above-mentioned facts and the evidence presented at the court of the first instance as well as the above evidence

full view of the following circumstances, which are found to have added the entire purport of the pleading, the

J. Of the amounts deposited into the instant borrowed account, the remaining part of the amount that the Defendant reduced as above shall be left to each other.

It is difficult to find that the Plaintiff did not have any omission in withdrawal. Ultimately, the name of the instant tea.

Each disposition of this case where the notice of sales of considerable part of the money deposited in the account was omitted.

The portion in the year 2002, 2003, and 2007 is legitimate, and the plaintiff's assertion in this part is without merit.

① Each statement of the above AA and BB, Plaintiff’s trade structure, transaction counterpart, etc.

in cash in addition to the use of the instant borrowed account in light of the circumstances in which the Plaintiff was able to do so

It appears that there was a high probability that there was a division, and furthermore, the third person other than the instant borrowed name account.

It is difficult to readily conclude that there is no possibility that the account has been used. Moreover, the instant borrowed name system cannot be readily concluded.

Examining the details of the coordinates (No. 119), the amount deposited in cash shall be equal to the OO won.

C.O20 U.S. O.C. O.O. branch (Transaction Branch Code, No. 20)

in cash, the amount of money deposited into the instant borrowed account without passbook shall be verified as OO won.

(f) has received all the proceeds of the goods into a corporate account or a borrowed-name account, and shall receive them in cash only once.

there is no fact that the money deposited in the borrowed account is transferred to a corporate account in cash.

(B) The Plaintiff’s assertion is significantly inconsistent with the Plaintiff’s assertion.

2. Moreover, AA himself/herself has some sales accumulated from the prosecution from 2002 to 2007.

In view of the fact that the plaintiff's sales is recognized (a total of approximately O00 won), omission of the plaintiff's sales

In determining whether or not the plaintiff was a party to the business year, the plaintiff issued a tax invoice and sold.

the sum of the 'amount deposited in the name account of this case' and the 'amount deposited in the corporate account of the plaintiff'.

Finding the Plaintiff’s assertion that there was no omission in sales on the sole ground that there was a large number of reasons;

In addition, the Plaintiff’s share of the Plaintiff in a different way by dividing the Before and after 2008.

Although it is argued that the omission in withdrawal should be determined, the grounds for understanding the omission in withdrawal should also be satisfied.

There is no time limit.

③ Rather, the Plaintiff’s type of transaction and characteristics of the type of business, and the use and use of the instant borrowed account.

period, the details of the deposit into the instant borrowed account, the statement of the final trading office (O's general company,O's industry), etc.

In light of the above, all of the money deposited in the name account of this case was reported to sell, and the false tax calculation.

The plaintiff's assertion that there was no omission of output tax amount, although the certificate was issued, is very unusual.

Therefore, the proof of special circumstances should be supported.

④ However, the Plaintiff is not a sales revenue omitted from the money deposited in the instant borrowed account.

Although it must be proved that the original market and objective data to support the plaintiff's assertion are necessary.

Rather, the Plaintiff’s assertion in the first instance court and the first instance court is not consistent, and the Plaintiff’s assertion is not consistent;

According to the results of the party's personal examination of AA in the trial of the party, the statement of AA is asserted by the plaintiff.

The name of this case, not the account of AA itself, is excessively contradictory or inconsistent;

Part on the circumstances in which the account has been used (A) of the Party’s personal examination result, No. 11;

12) Also, it is difficult to easily accept the Plaintiff’s assertion.

(5) In other words, AA and BB shall be listed in the OO, regional tax office, and prosecutor's office, and "OOcare other raw materials."

No sales tax invoice shall be issued because the listed goods, etc. purchased do not issue a purchase tax invoice;

The Plaintiff stated to the effect that it was “..........., the Plaintiff used the instant borrowed name account and the purpose thereof.”

the first instance court, for the purpose of resolving the defect problem of the product to the final buyer.

In order to make a transaction with the intermediate wholesale market (so called 'Sama'), the Gama has made a small scale and has not made a business registration.

In the absence of fault, the instant borrowed account was used, and the tax invoice was issued in the name of the final purchaser.

corporation that purchased raw materials in the trial, and in the trial, "the corporation that purchased the raw materials" shall be the large enterprise (OBK).

Although there was no problem, due to the characteristics of the type of business, the scale of the final buyer is small, and the scale is small.

A transaction through B, without issuing a tax invoice in the name of the final purchaser, and without issuing the tax invoice in the name of the final purchaser.

In such a way that it is difficult to obtain, such as asserting another purport that the sales proceeds have been received by the account holder.

It shows that it is.

Examining the statements of the above AA and BB more closely, A and BB shall be examined.

O In the regional tax office, the sales proceeds received from the instant borrowed account and taxes from the property, etc.

purchase of raw materials without invoice and nature in the process of producing products using the above raw materials;

A reduction shall be made to cover the loss incurred (which account for about 40 per cent of a large number of 'law', 'law').

AA, in particular, means the OVC’s raw materials of the primary product(PVC) in the prosecution.

purchase and supply products again to OBK after they are produced, and OBK's OBK

As raw materials contain a large number of co-rating agents, waste plates purchased from other enterprises in cash shallO;

The products were manufactured by mixing them with the raw materials of the Kenya, and were purchased as non-material. The portion above is the product.

of this case, the portion of the amount deposited into the name account of this case in the purchase of losses and raw material;

The plaintiff made a statement to the effect that the plaintiff failed to report the sales. As a result, the plaintiff made the following statement.

The statement that the account was used and the report of sale was omitted is far more than the plaintiff's assertion in the trial.

There is natural and persuasive power.

6. The Plaintiff’s supply of goods to Gamba for a long time, as alleged by the Plaintiff.

With respect to the maintenance of the type of transaction in which payment has been received from the date of this case to the borrowed account, each

In addition to the tax evasion by omitting entry, it is doubtful whether the plaintiff has any practical benefit.

In other words, the result of the party's personal examination of AA in the trial and the plaintiff's preparatory documents on November 8, 2016

As can be confirmed in all cases, both the final purchaser that issued the Plaintiff or the tax invoice;

Inasmuch as the existence is known, [A as a result of the party's personal examination to A, the recording page No. 24, etc.]

It imposes unnecessary expenses, such as brokerage commission, by participating in the middle of transaction.

It is difficult to find out the grounds therefor, and even if the status of other types of business is examined, the plaintiff's assertion.

It is not easy to find any form of transaction.

Accordingly, the plaintiff has technical expertise in chemical products.

If there is a defect in the product, the final buyer's demand for return, etc. shall be responsible and dealt with.

Although it was argued that there is a need to deal with the Plaintiff's business period, the Plaintiff's business period;

Considering sales, etc., it is difficult to consider that specialized knowledge is less than that of the Plaintiff.

In addition, in consideration of the return of defects in the product from the final buyer's standpoint, it is small to take into account the goods.

products on behalf of the plaintiff seems to have been favorable to the transaction with the plaintiff, and Rama seems to have been favorable to the transaction with the plaintiff.

It is difficult to accept easily the assertion that he/she will assume all responsibility for any person.

7. The Plaintiff is objectively able to identify the substance of the Plaintiff’s business and the transaction with the Plaintiff’s business.

Data(the essential measurements, measurements, in the light of the characteristics of the types of waste resources requiring the contract, measurement procedures;

A certificate, etc.) was not submitted and was prepared after the plaintiff (the plaintiff was 13 years).

A witness who has traded is also omitted from the above data only.

Moreover, it is necessary to find out the details of the deposit made by the Plaintiff from the instant borrowed name account.

In addition, it is not likely that Gyman used the name again from the borrowed name account.

On the other hand, the final customer in the sales tax invoice issued by the Plaintiff is the form of the Plaintiff’s assertion.

The room is denied.

8. The plaintiff was subject to prosecution's decision not to prosecute the violation of the Punishment of Tax Evaders Act.

Prosecutor's office recognizes that the Plaintiff received the price of the goods in the instant borrowed account, but only "the Plaintiff"

not only a copy of the tax invoice issued by the corporation, but also a borrowed account of this case

A report of approximately KRW 000,000 out of the amount entered, and a report of actual sales of at least KRW 00,000 has been filed.

In light of the above, sales are made solely on the ground that the Plaintiff received the sales price through a borrowed account.

The reason is that it is difficult to regard it as evasion of taxes by omitting it. However, the prosecution's failure to pay taxes is cited.

The burden of proof is different from the disposition of prosecution in the lawsuit in this case, and above all, the disposition of non-prosecution is subject to the above disposition.

In particular, as to "the fact that he reported approximately KRW 00 million out of the amount deposited in the name account of this case"

It is difficult to find objective evidence, and the lawsuit of this case is brought solely on the ground that the above disposition of non-prosecution is rendered.

In this regard, it is difficult to view that the Plaintiff fulfilled the burden of proof.

2) Of each disposition of this case, the parts concerning omission of sales in the year 2004 through 2006

A) Slaughterer, Gap evidence 108-3 through 5, Gap evidence 117-3 through 5, Gap evidence 118, 119;

123 to 125, the purport of the whole pleadings is shown in each description of the evidence submitted in the trial of the court.

In this case, ① the sum deposited in the Plaintiff’s corporate account in 2004 is the total amount of OO, and this case

The amount deposited into the borrowed Account shall be the total of the OOO, and the plaintiff shall calculate the tax of the total OO members.

(2) deposited in the Plaintiff’s corporate account in 2005.

The total amount of OOO, and the amount deposited in the name account of this case shall be the total amount of OOO.

The plaintiff issued a tax invoice of the total OO members and reported sales in 2005.

(3) The sum deposited in the Plaintiff’s corporate account in 2006 is the total amount of OO, and the instant tea.

The amount deposited in the name account shall be the total of the OO members, and the plaintiff shall calculate the amount of tax of the OO members.

It is recognized that the issuance of the certificate and the report on sales in 2006 have been made.

B) However, in light of the above circumstances, the evidence as well as the purport of the entire pleadings.

In addition to the following circumstances, the Plaintiff was also deposited into the instant borrowed name account:

Each of the dispositions of this case in 2004, in respect of which a significant portion of the money was omitted;

The part of the year 2006 is legitimate, and the plaintiff's assertion on this part is not justified.

① As seen earlier, deeming that the Plaintiff did not have omitted the part of cash sales during that period.

In light of the fact that it is difficult to do so merely as alleged by the Plaintiff, in the case of between 204 and 206.

In the sum of the Plaintiff’s “amount of deposits in the corporate account” and “amount of deposits in the borrowed name account of this case”, the Plaintiff shall calculate the tax.

only the amount equivalent to the difference calculated by subtracting the amount reported on sales by issuing the certificate shall be deemed to be an omission in sales.

No reasonable grounds are found.

(2) The defendant shall make a decision on re-audit by the Director of the Tax Tribunal on the plaintiff.

According to the results of the tax investigation, evidence, etc. submitted by the plaintiff out of the amount of the borrowed account of this case

Only the remainder other than the supporting part of the circumstances that cannot be deemed as an omission in sales shall be filled by

Each disposition of this case was taken in consideration of the omission amount of withdrawal.

③ In light of the legal principles as seen earlier, the Plaintiff is equivalent to the money deposited in the instant borrowed name account.

The plaintiff's assertion rather than the plaintiff's assertion without proving that the portion was not the amount omitted in sales.

In the light of the parties' personal examination results, etc., of AA in this consistent trial.

Even if it is difficult to believe, it is difficult to believe.

3) Of each of the dispositions in this case, the omission of sales in the year 2008 through 2012

The court's explanation about this part of the grounds for the judgment of the court of first instance

(d) Inasmuch as the entry is the same as the entry, under Article 8(2) of the Administrative Litigation Act, the main sentence of Article 420 of the Civil Procedure Act

this shall be cited as it is.

C. Sub-committee

Therefore, a significant portion of the money deposited by the Defendant in the instant borrowed account against the Plaintiff is sold.

Each disposition of this case, which deemed the omission of the report, is legitimate, and the plaintiff's assertion is without merit.

4. Conclusion

Thus, among the lawsuits in this case, the defendant's notice office of change in income amount belonging to year 2012 against the plaintiff

SectorA disposition to impose corporate tax for the year 2012 and a disposition to impose tax on each of the first earned income tax for the year 2012 as corrected.

Any lawsuit seeking revocation of any portion in excess of the amount shall be dismissed as it is unlawful, and the above

The plaintiff's remaining claims, other than the dismissed part, shall be dismissed for reasons without merit, and No. 1

The judgment of the court is unfair with some different conclusions, and thus, the defendant's appeal is partially accepted.

The judgment of the court is to be modified as above, and it is so decided as per Disposition.

The court's explanation on this part is the same as the corresponding part of the reasoning of the judgment of the court of first instance, and thus, this part is cited by Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. Whether the lawsuit of this case seeking revocation of the part exceeding the corrected amount among the dispositions of notification of change in the amount of income reverting to year 2012, the disposition of imposition of corporate tax reverting to year 2012, and the initial disposition of imposition of tax on earned income in the beginning is legitimate

(a) Notification of the change in the income amount reverted to year 2012 and disposition of imposing corporate tax reverted to year 2012;

1) We examine ex officio the legal nature of the instant lawsuit seeking each revocation of the disposition of notice of change of income amount attributed to year 2012 and the disposition of imposition of corporate tax belonging to year 2012.

2) Comprehensively taking into account the following evidence: (a) the Plaintiff reported the tax base and tax amount of corporate tax for the year 2012 to the Defendant on March 29, 2013, (b) the OO regional tax office notified the Plaintiff on June 5, 2014 of the results of re-audit according to the Plaintiff’s decision of the Tax Tribunal and notified the Plaintiff of the amount of corporate tax for the year 2012 and the amount of tax for the notice of change in income amount, (c) the OO regional tax office notified the Defendant of the results of re-audit on June 23, 2014, and the fact that the Defendant determines ex officio the amount of corporate tax for the year 2012 and the amount of corporate tax for the year 2012.

In light of the above facts, based on the corporate tax amount for year 2012 reported by the Plaintiff, the Defendant calculated the legitimate corporate tax amount and the notice of change in income amount, and reduced the Plaintiff’s content ex officio, and did not take any separate disposition, such as the notice of change in income amount for year 2012 and the disposition of imposition of corporate tax for year 2012, on the basis of the corporate tax amount for which the Plaintiff reported. If the Plaintiff objects to the amount reduced ex officio, the Plaintiff filed a claim for correction against the Defendant, and if the Defendant did not accept the above request for correction, it would have to bring an appeal against the disposition of refusal against the Defendant’s request for correction. Ultimately, among the instant lawsuit, there is no part seeking the revocation of the disposition of change in income amount for year 2012 and the

B. Part of the first imposition of wage and salary income tax, which exceeds the corrected amount

1) We examine ex officio the legality of the instant lawsuit seeking revocation of the part exceeding the corrected amount among the imposition dispositions of each of the first wage and salary income tax in the instant lawsuit.

2) As seen earlier, on June 23, 2014, the director of the regional tax office notified the Defendant of the result of re-audit to the effect that the imposition of tax on each of the earned income was corrected as stated in the attached Table No. 4, and accordingly, the Defendant issued a disposition to reduce or correct the imposition of tax on each of the earned income on June 25, 2014.

Therefore, the subject of an appeal shall be the remaining part of the first imposition disposition of wage and salary income tax, as seen above, and the lawsuit seeking revocation of the portion exceeding the corrected amount among the imposition disposition of wage and salary income tax at the beginning of the lawsuit in this case is revoked and unlawful as it is subject to non-existent disposition.

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

A. The Plaintiff’s assertion, relevant statutes, and relevant legal principles are as stated in each corresponding part of the reasoning of the judgment of the court of first instance (Article 2-2(a), (b), and (c)). Thus, they are cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

B. Determination

1) From among the dispositions of this case, the Defendant analyzed the following circumstances: (a) the Plaintiff’s 202, 203, 207, and 108 No. 1,2,6, and Gap’s 117-1, 2,6, Gap’s 118, 121, 122, and 126 of the evidence submitted at the trial; (b) the Plaintiff’s witnessCC’s testimony at the trial; (c) the Plaintiff’s representative director at the questioning of the Party A of the facts charged of the Plaintiff’s own account; and (d) the Plaintiff’s 200,000,000 won, which were not reported and issued at the 200,000 won, for each of the instant accounts (the 207,000 won, which were not reported and issued at the 207,000,000 won, respectively, of the instant accounts omitted from the 207,000 won, respectively.

Therefore, in addition to the detailed reality where the use of a borrowed account is frequent for the purpose of tax evasion through the reduction of sales and the difficulty of proof between the parties, it is reasonable to comply with this Opinion.