The costs of appeal are assessed against the defendant.

Article 41 of the Framework Act on National Taxes and Article 22 of the Enforcement Decree of the same Act refer to a person who has comprehensively succeeded to all rights and obligations concerning the business, and it is a party member's case where the transferee must be a person who has succeeded to the legal status to the same extent as the transferor by taking over all rights and obligations concerning the business as well as business facilities and all rights and obligations such as goodwill and claims and obligations concerning the business (see Supreme Court Decision 81Nu134 delivered on December 13, 1983; Supreme Court Decision 82Nu311 delivered on April 24, 1984).

According to the facts duly established by the court below, the plaintiff acquired only 47 kinds of tools, including the first-class electrical construction business license of the non-party company and the second-class construction section 28 of the non-party company's ownership, from the non-party company's non-party company's non-party company's non-party company's KRW 27,00,000,000, and did not acquire other business facilities, human resources, and rights. Thus, the decision of the court below to the same effect is justified.

In conclusion, the judgment of the court below is without merit, and there is no violation of the rules of evidence and mistake of facts, and the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the

Justices Lee Il-young (Presiding Justice)