On September 20, 1996, 23 E Association (hereinafter “Union”) was established on September 20, 1996, including C and DoD (the death on May 19, 2009, hereinafter “the deceased”), which were owners of the aggregate of 3,775 square meters (hereinafter “instant land”), and 23 persons (the number of partners reduced 17 persons thereafter; hereinafter “members”) who were owners of the instant land, Jung-gu, Seoul, and 12 square meters (hereinafter “instant land”).

On December 30, 200, the instant association newly constructed a F building consisting of 1,878 stores on the instant land (hereinafter “instant commercial building”) and completed registration of initial ownership in the name of the instant association on January 11, 2001, and sold 1,600 stores to the general public, and entered into an additional contract for land use with the content of giving the buyer the right to use the land which is the object of the right to the site of the store sold between the buyer and the buyer for 30 years, and received the aforementioned 1,14.1 billion won advance payment from the buyer.

The association of this case paid value-added tax from 2001 to 2008 on the amount calculated by dividing the above land rental fee into the rental period (30 years) and the respective sales area as the supply price by treating the above land rental fee as the player rental fee (hereinafter “the rental fee of this case”). As to the revenues of the rental fee of this case from the members of the association registered with the National Tax Service each year, the association of this case prepared a detailed statement of distribution by joint business proprietor according to

On August 16, 2016, the Defendant: (a) deemed that the deceased’s heir was liable to pay rental income equivalent to 9.99% of the deceased’s share in the year-2009 to 2013 of the rent for the player of the instant association; and (b) deemed that the Defendant was liable to pay the deceased’s heir for the rental income equivalent to the Plaintiff’s share in the inheritance (14%) amounting to 19,74,971 won (the Defendant’s income from the rent for the player of the taxable period after the deceased’s death from the date of the death).