A. A Co., Ltd. (hereinafter “A”) was a corporation established for the purpose of automobile transportation business, etc. on July 30, 1970, and closed on March 16, 2010 after the delinquency of value-added tax, corporate tax, and comprehensive real estate holding tax as follows:

Tax items in arrears (unit: 13,675 9,924 3,751, 201.3.16 March 16, 2010, comprehensive real estate tax on March 2, 2010, 9,4267, 639 1,787, 787, 787, 201. < Amended by Act No. 10101, Jun. 1, 2011>

The Defendant deemed that the Plaintiff acquired 87,524 shares A (98.48%; hereinafter “instant shares”) out of 88,875 shares issued by means of a transfer security agreement, and accordingly, the Defendant designated the Plaintiff as a secondary taxpayer for the first period of May 22, 2013 and imposed the imposition of value-added tax of 13,46,850 won (value-added tax 9,773,76,130 won, additional tax of 3,693,720 won) for the first period of May 27, 2013, and notified the Plaintiff of the imposition of the comprehensive real estate holding tax of 143,238,610 won (value-added tax of 106,427,150 won, additional tax of 36,811,480 won) for the year 2010.

(hereinafter “instant disposition”). C.

On September 12, 2013, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on November 5, 2013, and the Tax Tribunal dismissed the decision on May 19, 2014.

【Ground of recognition】 The fact that there has been no dispute, each entry of Gap 2, 6, and 7 evidence, and the purport of the whole pleading

2. The plaintiff's assertion

A. The Plaintiff, as a creditor to A, received the instant shares as a security for transfer in order to recover the loan, and did not actually exercise the right to shares.

B. In addition, in applying the provisions of Article 151(1) of the Enforcement Decree of the Income Tax Act to the transferred asset, where the debtor concludes a contract to transfer the asset to secure the repayment of the obligation, the following requirements are satisfied: