A. B Co., Ltd. (hereinafter “instant company”) is a corporation incorporated on April 25, 2008 for the purpose of the instant wholesale business.

According to the “Detailed Statement on Change in Stocks, etc.” submitted by the instant company from the business year of 2008 to the business year of 2016, 70% out of the total number of issued stocks of the instant company 10,000, CA, the representative director of the instant company, 20%, D, and 10%, respectively, appears to have been held by the Plaintiff.

On the other hand, the plaintiff is a child of C, and D is a spouse of C.

B. After conducting a tax investigation with respect to the instant company, on December 7, 2016, the Defendant did not issue a tax invoice even if the instant company sold steel bars to the seller, and omitted the amount of income using a borrowed account. As indicated in the attached list 2, the Defendant issued each notice of imposition of KRW 833,469,300, totaling KRW 852,576,170 (hereinafter “disposition with respect to the instant company”) from the year 2008 to the second year 2015 as the corporate tax from the year 2008 to the year 2015.

C. However, since the instant company closed its business on December 31, 2016 and did not pay corporate tax and value-added tax imposed and notified in the instant company as above, the Defendant, on February 21, 2017, deemed the Plaintiff to be an oligopolistic shareholder of the instant company, designated the Plaintiff as the secondary taxpayer on February 21, 2017, and imposed upon the Plaintiff each of the corporate tax and value-added tax equivalent to 10% of the corporate tax and value-added tax imposed and notified in the instant company as shown in the separate sheet No. 1 list (hereinafter “instant disposition”).

On April 21, 2017, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal. However, the Tax Tribunal dismissed the Plaintiff’s appeal on November 2, 2017.