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

The reasoning for this part of the judgment is as follows: (a) the part of the judgment of the court of first instance (hereinafter referred to as “instant disposition”) with “3 2 -4 -0 -0 -0 -0 -0 -0 -0 -0 -0 -0 -0 - 0 -0 - 0 -0 - 0 -0 - 0 -0 - 0 - and 1)”

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

1) In order to establish a corporation, the Plaintiff only lent to BB only the name for holding shares with the advice of a certified judicial scrivener that the shareholder should be at least three persons, and did not participate in the operation of the instant company. The Plaintiff received benefits as an auditor or received dividends as a shareholder. Moreover, the Plaintiff was raising business income in operating the instant company separately. Accordingly, the Plaintiff is not a real shareholder of the instant company, and the Plaintiff cannot be deemed a secondary taxpayer for the instant company. Accordingly, the instant disposition on a different premise should be revoked as unlawful.

2) The instant company did not engage in an active act to evade national taxes, but merely did not report the sales amount under itself. Thus, it cannot be deemed as a “Fraud or other unlawful act” as stipulated in Article 26-2(1)1 of the Framework Act on National Taxes. Therefore, the portion of the disposition against the instant company, among the disposition against the instant company, between the year 208, 2009, and the year 2010 and the year 2008 and the year 1, 2011, is unlawful after the lapse of five-year exclusion period of imposition under Article 26-2(1)3 of the Framework Act on National Taxes, and based on the subsidiary nature of the secondary tax liability, among the disposition against the Plaintiff, the period of imposition of five-year exclusion period of imposition under Article 26-2(1)3 of the Framework Act on National Taxes.

value-added tax shall also be revoked in an unlawful manner.

B. Relevant statutes

Attached Form 3 shall be as listed in attached Table 3.

C. Determination

The reasoning for this part of this Court’s judgment is as follows: (a) the reasoning for this Court’s judgment is as stated in the reasoning from the last 4th to 8 bottom of the judgment of the first instance (hereinafter referred to as “written judgment of the first instance”) in addition to the parts to be written or added below; (b) therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

○ At the bottom of 5, up to 3, 6, and 7 'two Evidence' consisting of "A3, 5, 6, 7, 10, 10, 1, 1, 5."

○ 6 4 pages "(1,2)" shall be added to the following:

○ 6 10 pages "(the same shall apply even if it takes into account each description of evidence A16, 17, and 18)."

○ 3 to 8,00,000 won, respectively, was deposited in cash from the account of the above community credit cooperative under the name of BB on April 22, 2008, and from April 25, 2008, respectively. The amount of KRW 50,000,000,000 to the account of the Bank in the name of the instant company was deposited in the account of the Bank on May 2, 2008, and immediately thereafter deposited KRW 50,000,000,000,000 won was deposited in the account of the said community credit cooperative on the same day, even though it is recognized (Articles 7-1 and 2 of evidence 7), it cannot be readily concluded that BB was funded, and even if the above KRW 50,00,00,000,000 was funded, the Plaintiff’s shares were 1,000,000 won and 50,000,000 won (BB).

In light of the fact that the company's income and assets in this case were not distributed to the company 6th and 3rd under 6th and later, "No. 3-1", the company in this case was actually one of the 2BB's management judgment, and that the 2B's income and assets acquired from the business were managed and consumed through the account of the individual in BB, and that CCC, the head of BB, assisted the company in this case and operated separate businesses from 2001, and the plaintiff could not be expected to use the company's income and assets for the plaintiff in this case, and there was no fact that the plaintiff received benefits, the company in this case did not actually exercise the right as the shareholder of the company in this case or take an economic profit from 50 billion won (see, e.g., Supreme Court Decision 200 million won, and it cannot be viewed that the company's income and assets were managed only through the account of the company in this case 7B's income and assets in this case 80 billion won (see, 70 billion won).

○ From 7 pages to 2, “Judgment” is added to “Supreme Court Decision 2014Du2522 Decided September 15, 2015”.

3. Conclusion

Therefore, the plaintiff's claim shall be dismissed as it is without merit. The judgment of the court of first instance is unfair on the basis of a different conclusion (the part concerning the additional dues in the disposition of this case shall not be deemed to be unlawful since the part concerning the disposition of this case constitutes the disposition subject to appeal litigation) but the part concerning the disposition of the additional dues in this case shall not be deemed to be unlawful among the lawsuits of this case where only the plaintiff appealed cannot change the judgment of the court of first instance disadvantageous to the plaintiff, and it is so decided as per Disposition.