2. The costs of lawsuit shall be borne by the Plaintiff.

23 persons, including the Plaintiff, etc. (including the Plaintiff, etc., who were owners of B and B, and 3,775 square meters (hereinafter “instant land”), established the C Association on September 20, 1996 (hereinafter “instant association”) for the purpose of newly building a commercial building on the instant land to sell in lots and engage in leasing business.

On December 30, 200, the instant association newly constructed D Building consisting of 1,878 stores on the instant land (hereinafter “instant commercial building”) and completed registration of initial ownership on January 11, 2001 in the name of the instant association.

Around 200, the instant trade association sold 1,600 stores of the instant commercial building and registered the instant land in the name of 23 persons, including the Plaintiff, etc., and entered into a land use contract (hereinafter “the instant land use contract”) with the buyer in return for granting the buyer the right to use the instant land for 30 years and receiving land usage fees in advance from the buyer (hereinafter “the instant land use contract”), and received advance payment from the buyer.

The Defendant is an organization, other than an organization deemed a juristic person under the Framework Act on National Taxes, and the method of distributing profits or the ratio of distributing profits is determined or actually distributed, so the Plaintiff, a partner of the instant case, was liable to pay income tax on the portion equivalent to the Plaintiff’s share ratio (3.5%) out of the pertinent usage fees (hereinafter “shared usage fees”), and on the ground that the Plaintiff did not file a return on the key usage fees when filing a comprehensive income tax return for the year 2012 and 2013, on April 25, 2017, on the ground that the Plaintiff did not file a return on the key usage fees income (including additional tax) with respect to the Plaintiff on April 25, 2012, the global income tax of KRW 65,943,020 (including additional tax), and the global income tax of KRW 61,171,050 (including additional tax)