A. The Plaintiff and B are married couple.

B. From January 1, 2006, the Plaintiff operated Dental department C in Ulsan-gu, Ulsan-gu (hereinafter “instant dental department”). On December 31, 2010, the Plaintiff transferred the instant dental business to B in KRW 914,900,000 for price.

C. After acquiring the instant dental license, B treated KRW 320,000,000, out of the acquisition price for the income from the operation of the instant dental license as necessary expenses ( KRW 64,000,000, KRW 128,000,000, KRW 128,000, and KRW 128,000,000, and KRW 128,000,000), and assessed the total income tax.

On August 1, 2017, the Defendant: (a) deemed that the de facto owner of the instant dental income was liable to pay the Plaintiff on the ground that he/she was the Plaintiff; (b) accordingly, the Plaintiff was liable to pay global income tax of KRW 64,914,130 for the year 2013; (c) global income tax of KRW 110,583,280 for the year 2014; and (d) global income tax of KRW 96,191,470 for the year 2015; and (c) global income tax of KRW 271,68,880 for the year 2015 (hereinafter “instant disposition”).

E. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on September 12, 2017, and the Tax Tribunal dismissed the appeal on December 8, 2017.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff asserted that the Plaintiff actually transferred the instant dental business to B, and thus, the instant disposition that is based on the premise that the de facto owner of the instant dental income is the Plaintiff is unlawful.

B. The Defendant’s assertion is unclear in the nature of the transfer price of the instant dental license. After transferring the instant dental license, the Plaintiff’s status and role are identical, and related persons, including the Plaintiff, were the Plaintiff as the Plaintiff in the course of tax investigation.

Therefore, the transfer and acquisition of the instant dental license between the Plaintiff and B is the most trade, and the actual owner of the instant dental income is still the Plaintiff. Therefore, the instant disposition is lawful.

(c).