2. On April 4, 2007, the claim for revocation of the imposition of global income tax against the Defendant of the Plaintiff Han-gu District Tax Office on April 4, 2007, and the claim for revocation of the imposition of corporate tax against the Defendant of the Plaintiff ○○ Housing Co., Ltd. is dismissed

3. The costs of lawsuit are assessed against the plaintiffs.

2. On September 1, 2006, the part of the disposition imposing value-added tax exceeding KRW 50 million among the disposition imposing value-added tax of KRW 60,479,740 for the second period (the first period portion of the Director seems to be a clerical error), the part exceeding KRW 100 million among the disposition imposing value-added tax of KRW 120,05,530 for the first period (120,000,000, KRW 101,964,810 for the second period (200, KRW 100, KRW 88,827, KRW 910 for the second period), the part of the disposition imposing value-added tax of KRW 200, KRW 206 for the second period (the imposition disposition imposing value-added tax of KRW 8,827, KRW 910 for the first period, KRW 200, KRW 2006 for the second period (the imposition disposition imposing value-added tax of KRW 200636,7000,0000.7.

3. On October 10, 2006, the disposition of imposition of value-added tax amounting to 21,602,450 won for the second period of 2006 against the plaintiff Kim Jong-young shall be revoked.

4. The head of the regional tax office’s imposition of KRW 1,256,453,120 of global income tax for 2001 on April 4, 2007, the part exceeding KRW 125,645,310 of the disposition of imposition of KRW 100,000 of global income tax for 201 (income tax) and KRW 356,527,920 of global income tax for 201 and KRW 35,652,790 of the disposition of imposition of KRW 30,000 of global income tax for 201 on May 1, 2007 shall be revoked.

5. On March 10, 2007, the disposition of imposition of the corporate tax of KRW 370,652,550 imposed on the Plaintiff ○○ Housing Co., Ltd. for the year 2001 shall be revoked.

6. On March 10, 2007, the notice of payment of KRW 370,652,556 of the corporate tax of KRW 370,652,556 of the Plaintiff’s ○○ Housing Co., Ltd., which the director of the tax office of the Korea-do District Tax Office rendered against

7. On April 30, 2007, the notice of payment of KRW 48,184,830 of the corporate tax for 2001, the Plaintiff ○○ Housing Co., Ltd., which was issued by the head of the Defendant Dobong Tax Office with respect to the Plaintiff Kim Jong-si was revoked.

8. On February 22, 2007, the head of the defendantdobong Tax Office’s notice of change in the income amount of the Plaintiff’s ○○ Housing Co., Ltd. [the notice of change in the income amount [the notice of (1) 2.81, 859, 484 won and (2) 781, 859, 484 won and (3))

A. On September 1, 2006, the head of Samsung Tax Office (the Defendant is not the Defendant) imposed value-added tax of KRW 93,512,660 on the Plaintiff’s Hansung on September 1, 2006, and imposed value-added tax of KRW 80,676,040 on October 1, 2004 and the value-added tax of KRW 80,676,040 on the second and second term portion (the disposition related to the claim 1.).

B. On September 1, 2006, the director of the regional tax office imposed the Plaintiff Kim Jong-si value-added tax of KRW 60,479,740 on September 1, 2006, ② value-added tax of KRW 120,05,530, ③ value-added tax of KRW 101,964,810, ④ value-added tax of KRW 88,827,910, ⑤ Value-added tax of KRW 827,910, ⑤ Value-added tax of KRW 88,790, KRW 420, and KRW 66,732,710 for the second half of year 2003 ② Value-added tax of KRW 1,204 (“value-added tax”) on KRW 1,205, and KRW 30 for the second half of year 200” (value-added tax of KRW 66,732,710 for the first half of year 2006).

C. On October 10, 2006, the director of the final tax office imposed the value-added tax of 21,602,450 won on the Plaintiff Kim Jong-si for the second half year of 2006 (the disposition stated in paragraph 3.).

D. 1) While the Plaintiff, ○○ Housing Co., Ltd. (hereinafter “Plaintiff”) promoted the instant new construction project on the ○○○○○-dong, Seoul, ○○○-1 and three parcels of land (hereinafter “instant new construction project”), on May 19, 200, the Plaintiff transferred the instant new construction project to ○○ Construction Co., Ltd. (hereinafter “○○○ Construction”). In this regard, on February 15, 2007, on the part of the Plaintiff, the director of the tax office rendered a notice of the change in the amount of bonus corresponding to KRW 2.8 billion (hereinafter “the balance”) from the remainder of the transfer price to ○○ Medical Co., Ltd. (hereinafter “the instant transfer price”). In addition, on February 15, 2007, the director of the tax office rendered a notice of the change in the amount of bonus income (hereinafter “the disposal of the instant new construction project”).

2) On April 4, 2007, the director of the regional tax office imposed KRW 1,256,453,120 of global income tax for 201 and KRW 125,645,310 of resident tax (pro rata income tax) for 2001 on the Plaintiff Han-gu, respectively, according to the notice of change in the amount of income under the above paragraph (1) of the above Article (each disposition stated in paragraph (1) of the claim).

3) On June 14, 2007, Plaintiff Han-he filed a request for a trial with the National Tax Tribunal on the disposition of imposition of global income tax as stated in Article 4-1(1) of the purport of the claim on April 14, 2007. The National Tax Tribunal rendered a decision to dismiss the above request for a trial on December 31, 2007.

E. 1) The director of the tax office of the Dowing Tax Office deemed that the instant construction price was omitted from the instant transfer price on the ground that ○○ Construction paid 781,859,484 won (hereinafter “the instant construction price”) to the subcontractor on behalf of the Plaintiff Company separately from the instant transfer price, and included it as “the transfer price of the instant new construction project” in the gross income for the business year 2001, and then took the following measures accordingly.

① On March 12, 2007, the Plaintiff Han-he notified the change in the amount of income to the effect that “the amount equivalent to the construction cost of the instant case shall be treated as a bonus reverted to the Plaintiff Han-gu column in 2001” (a disposition related to Article 8-2(2) of the Claim).

② On March 10, 2007, the Plaintiff Company imposed corporate tax of KRW 370,652,550 for the year 2001 (the disposition stated in the claim 5.).

③ On May 1, 2007, on the ground that he was the secondary taxpayer against the Plaintiff Company, he notified the payment of KRW 229,80,850 of the corporate tax amount under the above paragraph (2). (Disposition related to the claim 6.)

④ On April 30, 2007, on the ground that he was the secondary taxpayer against the Plaintiff Kim Il-young, he notified the Plaintiff company of the payment of KRW 49,630,370 of the corporate tax amount under the above paragraph (2). (Disposition related to the claim 7.)

2) In accordance with the notice of change in the amount of income under Paragraph (1) of the above 1 of May 2007, the director of the regional tax office of Korea imposed KRW 356,527,920 of global income tax for the year 2001 and KRW 35,652,790 of resident tax (income tax) for the year 2001 (each disposition stated in Paragraph (2) of the above 4.2 of the purport of the claim) respectively.

3) On June 8, 2007, the Plaintiff Company filed a request for a trial with the Tax Tribunal regarding the disposition of the disposition stated in Paragraph 5 of the claim and the construction cost of this case as bonus for Plaintiff Han-heat. On March 20, 2008, the Tax Tribunal decided to dismiss the Plaintiff Company’s request for a trial.

[Basis] Evidence Nos. 1-1, 2, 2-1, 3 through 5, Gap evidence Nos. 6-1 through 6, 8, Gap evidence Nos. 7 through 9, Eul evidence Nos. 1, 2, 3-1 through 6, 4, 5, 8 through 11, 20 through 22, 27, 28, 29-1 through 3 of evidence Nos. 29, the fact-finding results with respect to the Commissioner of the National Tax Service of this Court, the fact-finding results with respect to this Court, and the purport of whole pleadings

2. Whether the lawsuit of this case is lawful

A. Summary of the defendants' main defense

On the grounds that the plaintiffs sought revocation of each of the dispositions stated in the purport of the claim by the lawsuit of this case, the chief of the Dobong Tax Office and the chief of the regional tax office of the Dobong Tax Office are unlawful for the following reasons.

1) The Plaintiff Kim Po-so and Han-so filed the instant lawsuit without going through an administrative appeal by bringing about each of the dispositions stated in 3.3. of the purport of the claim, imposition of global income tax stated in 4.4.2 of the claim, and claim 6.6.7 of the claim.

2) The Plaintiff Kim Il-young filed the instant lawsuit after the withdrawal of the administrative appeal claim as to the disposition as stated in paragraphs (1) through (6) of Article 2-2 and the disposition as stated in paragraph (2) of Article 2.

3) After the decision of the Commissioner of the National Tax Service on the dismissal of the request for examination as to the disposition stated in 1-2 (2) of the purport of the claim, the Plaintiff Hansung filed the instant lawsuit with the lapse of the filing period.

4) Each disposition of imposition of the resident tax (income tax) stated in paragraph 4. of the purport of the claim is the disposition authority other than the chief of the regional tax office of the defendant.

B. Determination on this safety defense

1) There is no evidence to acknowledge that the Plaintiff Kim Po-so and Han-so filed an administrative appeal on each of the dispositions stated in 3.3 of the purport of the claim, imposition of global income tax stated in 4.4-2 of the purport of the claim, and claim 6.6 and 7 of the claim. Therefore, this part of the lawsuit by the said Plaintiffs is unlawful in violation of the proviso of Article 18(1) of the Administrative Litigation Act and Article 56(2) of the Framework Act on National Taxes, which were filed without going through a request for examination or a request for adjudication and a decision thereon

As to this, the Plaintiff asserted to the effect that “the Plaintiff Company, around June 2007, filed a request for a national tax trial on the notice of change in the amount of income as stated in Article 8-2(2) of the purport of the claim, which is a premise for the imposition of global income tax as stated in Article 4-2(2) of the purport of the claim.”

On the other hand, there is no evidence to support that the notice of change in the amount of income stated in paragraph 8. of the claim was given to the plaintiff company (this part of claim 8. of the claim is unlawful as a revocation lawsuit against the non-existent disposition). Furthermore, as seen earlier, the plaintiff company filed a petition with the Tax Tribunal for a trial on the disposition of imposing corporate tax stated in paragraph 5. of the claim and the construction cost of this case as bonus against the plaintiff Han○ column. However, corporate tax and global income tax are completely different from the tax items, and even if corporate income was generated from non-deductible expenses, even if it was reserved or leaked to the corporation, it cannot be deemed that the income belongs only to the representative even if it was reserved or leaked to the corporation, and thus, even if the corporation had gone through the pre-trial trial procedure for the disposition of imposing corporate tax and recognition, it cannot be deemed that it goes through the pre-trial procedure for the revocation of the disposition of global income tax against the person to whom the income belongs, and thus, it cannot be deemed that the plaintiff company's allegation in the above judgment is not necessary (see, 2006.).

In addition, we examine the following facts: (a) Disposition 6.1 of the purport of the claim is different from Disposition 1.5 (3) of the above 1.5 related to Disposition 6.1 of the claim; and (b) Disposition 7.1 of the claim is different from Disposition 1.5 (e.1) of the above 1.5 related to Disposition 7.1 of the claim; and (c) they cannot be deemed to actually exist. Thus, this part of the lawsuit is unlawful even in the case of revocation

2) According to the statement No. 6 of this Court's evidence, the fact-finding results with respect to the Commissioner of the National Tax Service, and the purport of the whole pleadings, the plaintiff Kim Jong-si filed a request with the Commissioner of the National Tax Service for an examination as to the disposition of No. 206-44 on Nov. 30, 2006 and the disposition of No. 2-2 (2) on Nov. 30, 2006, and it can be acknowledged that the cancellation was made on Feb. 13, 2007. Thus, this part of the lawsuit by the plaintiff Kim Il-young is unlawful as a revocation lawsuit filed without going through a request for examination or a request for adjudication

3) According to the statement Eul evidence No. 7 and the results of fact-finding with the Commissioner of the National Tax Service of this Court, the plaintiff Han-sung requested the Commissioner of the National Tax Service to examine the disposition as of November 30, 2006 as of Sep. 1, 2006, and on Feb. 20, 2007, upon receiving a decision of rejection from the Commissioner of the National Tax Service on the ground that "the right holder by the disposition was not subject to an infringement of interest, and he did not comply with the correction request within the correction period," the above decision was delivered to the plaintiff Han-sung's representative on the 28th of the same month, and the fact that the plaintiff requested the Commissioner of the National Tax Service for examination as to the disposition as of Oct. 10, 2006 as of Oct. 10, 2006, and the decision of rejection as to the disposition as to the claim No. 1-2 of the above plaintiff cannot be accepted from another premise.

However, this part of the safety defense is against the purport that "the plaintiff's only ○○ has not gone through a legitimate procedure of prior trial as to the disposition stated in 1. 2. of the claim." Thus, there is no evidence to prove that the plaintiff's only ○○○ has filed a request for examination or a request for examination as to the above disposition. Thus, this part of the lawsuit is unlawful as it is a revocation lawsuit filed without a request for

In addition, the disposition stated in Section 1.1-2 of the purport of the claim is unlawful even in the case where the disposition is a revocation lawsuit against a non-existent disposition, since the disposition and the tax amount of the above 1.1.a. are different, and there is no other evidence to prove its existence. Thus, this part of the lawsuit is unlawful.

4) According to Article 177-4(1), (2), and (5) of the Local Tax Act, when the head of a tax office collects income tax, he/she shall impose and notify income tax (income tax) along with income tax, and in such cases, the head of a Si/Gun/Gu (in cases of the Special Metropolitan City/Metropolitan City/Metropolitan City, the head of the Gu) having jurisdiction over the place for the payment of income tax shall be deemed to have imposed and notified each resident tax specified in Article 177-4(1), (2), and (5) of the Local Tax Act. Therefore, the disposition authority in charge of the imposition of each resident tax stated in Article 4(1) of the Local Tax Act shall be deemed to be the head of the competent tax office, not the head of the competent tax office, rather than the head of the competent tax office. Therefore,

C. Ex officio determination

1) As to the disposition stated in paragraph 1-1 of the claim

The above disposition is unlawful as a revocation lawsuit against a non-existent disposition, since it does not coincide with any of the dispositions in the above 1.A, and there is no other data to prove its existence, and thus it cannot be deemed that it actually exists.

2) As to the disposition stated in paragraph 2-1 of the claim

The above disposition is unlawful as a revocation lawsuit against a non-existent disposition, since it does not coincide with any of the dispositions in the above 1.A, and there is no other data to prove its existence, and thus it cannot be deemed that it actually exists.

3. Judgment on the merits

A. Whether the disposition of imposition of global income tax stated in paragraph (1) of 4. purport of the claim (hereinafter referred to as the "disposition of this case") is legitimate

1) Summary of the plaintiff Han-he's assertion

A) Notice of change in income amount, which is the premise of the instant disposition, was not legally served on the Plaintiff Company.

B) Although the instant disposition was premised on the premise that the instant balance belonged to Plaintiff Han-gu, the instant disposition did not actually belong to the said Plaintiff.

C) Despite the fact that the balance of this case belonged to the Plaintiff Company in the business year of 2000, not the business year of 2001, the instant disposition was premised on the notification of change in the amount of income, which was disposed of as “the bonus reverted to year 2001”.

(ii) the facts of recognition

가) 원고 회사는 ○○건설에 대한 이 사건 잔금채구†�우, 2000. 5. 26.에는 10억원 부분을 권○연에게 양도하고, 같은 해 6. 2.에는 8억 원 부분을 권○연에게, 10억 원 부분을 김○자에게 각 양도한다는 취지의 채권양도증서들(을 제17호증의 2 내지 4)을 작성하였다.

B) After that, ○○ Construction treated the remainder of the instant claim (total amounting to KRW 1.8 billion) that was transferred to ○○○○○○○ as an accord and satisfaction for the part of KRW 1.176 million as to the part of the instant claim (total amounting to KRW 1.8 billion), as transferring an apartment household to ○○○○○○○○ as an accord and satisfaction for the part of the instant claim (or from June 21, 200 to May 11, 2001, the remainder of the instant claim was treated as having been repaid to ○○○ and Kim○○○ (or from them to third parties, such as Cho○○, and Lee ○-ro). Meanwhile, it was treated as having been transferred to ○○○○○○○○○, and the rest of the household was treated as having been transferred to ○○○○○○,

C) The Plaintiff Company: (a) incurred an excess on the repayment of the remainder of the instant claims or payment in substitutes; (b) omitted accounting of the instant claims; or (c) recorded accounts as “payment in cash following cash payments” without any specific ground (the Plaintiff Han-gu, asserting that the above accounts are justifiable; (c) however, there is no evidence supporting the legitimacy of the above accounts.

D) Meanwhile, from around 200 to around 200, Plaintiff Han-dong borrowed a total of KRW 980 million from Kim Nam, and borrowed KRW 200 million from this accommodation.

E) In the tax investigation conducted by the National Tax Service, which was an opportunity for the instant disposition, the competent ○○○ and Kim○ stated to the effect that, without entirely aware of “the fact that they received the instant remainder claim, transferred it to a third party, received repayment or payment in kind, or transferred an apartment acquired through the payment in lieu of the instant remainder obligation to a third party”, the Plaintiff Han-he made the appearance of the said transaction without permission under his name.

F) In the above tax investigation, Kim Yong-Nam stated to the effect that he was transferred an apartment 6 household as above, as the payment in lieu of the claims that he would have been repaid from Plaintiff Han-dong column.

[Ground of recognition] The evidence Nos. 8 through 11, Eul evidence Nos. 17-2 through 4, Eul evidence Nos. 18, 19, Eul evidence Nos. 23-4, 5, 7 through 9, 11 through 13, and Eul's whole purport of pleading and arguments No. 24 through 26

3) Determination

A) As seen earlier (see the above paragraph 1.d.1) of the defendantdo chief of the tax office) notified the plaintiffdo chief of the tax office on February 15, 2007 that "the income amount shall be disposed of as bonus belonging to the business year of 2001 to the plaintiff Han○ column" to the effect that "the amount of the balance of the case shall be disposed as bonus belonging to the business year of 2001 to the plaintiff Han○ column," this part of the plaintiff Han○ column's assertion is without merit. Furthermore, in the case where the tax office disposes of the income as the payer of the income amount, it is established as withholding tax on the date when the notice of change in the income amount was served on the corporation as the withholding agent is served on the corporation. Unlike whether the notice of change in the income amount was served on the corporation, if the person to whom the income belongs is disposed of as a bonus, it constitutes "the amount disposed as a bonus under the Corporate Tax Act as provided in Article 20 (1) 1 (c) of the Income Tax Act, and thus, it is without merit in this part of this argument.

B) According to the above facts, the remaining amount of this case appears to have been actually used for the purpose of repaying the debt of the loan to Kim ○nam and Lee ○○○○○ by means of the Plaintiff, the representative director of the Plaintiff company, and the remaining amount of this case was all leaked out of the company and reverted to the Plaintiff Han ○○ column. The tax authority should dispose of the remaining amount as a bonus for the Plaintiff Han ○○ column pursuant to Article 106(1)1 (b) of the Enforcement Decree of the Corporate Tax Act. Even if the above facts were otherwise acknowledged, the tax authority should dispose of the remaining amount of this case as a bonus for the Plaintiff Han ○○ column, since it is judged that the remaining amount of this case was leaked out outside the company and it is unclear at least the ownership is unclear, according to the proviso to the same subparagraph, the tax authority should also dispose of it

As to this, the Plaintiff Han-gun asserts that the proviso of Article 106 (1) 1 of the Enforcement Decree of the Corporate Tax Act exceeds the delegation scope under Article 67 of the Corporate Tax Act, which is a superior law, and thus null and void. However, the disposal of income under Article 67 of the Corporate Tax Act is confirmed to be reserved inside or outside the company in determining or correcting the corporate tax base. If the amount is leaked out outside the company, it is a procedure under the tax law that determines the type of attribution and the type of income. It is a procedure to confirm ex post facto the income belonging to a specific taxable year. If it is obvious that the amount included in the gross income has already been leaked out the company, it shall be deemed that the group would have been attributed to the company, but if it is obvious that the amount included in the gross income would have been leaked out the company, it shall be deemed that Article 67 of the above Act includes "the amount included in the gross income shall be disposed of by the person to whom it reverts," and thus, it shall not be deemed that the above scope of disposal of income belongs to the company.

C) The instant disposition is premised on the premise that the instant balance belongs to, or is not clear to, the Plaintiff’s (not the Plaintiff Company) for, the business year 2001 (not the Plaintiff Company). As seen earlier, in filing a corporate tax return for the year 2001, the Plaintiff Company included the instant transfer proceeds in its gross income for the business year 2001 (including the instant balance) (Evidence No. 16). In addition, the instant disposition is deemed to have been deemed to have been attributed to, or unclear to, the Plaintiff’s Republic of Korea for the business year 2001, and it is insufficient to reverse the instant judgment solely on the ground that ○○ Construction paid part of the instant remainder debt in payment or payment in full for the business year 200. Thus, the Plaintiff’s assertion on this part is without merit.

D) Therefore, the Plaintiff ○○ fever’s assertion is without merit, and the instant disposition is not erroneous as otherwise alleged by the said Plaintiff.

B. Whether the disposition stated in Paragraph 5. (hereinafter in this paragraph referred to as the "disposition of this case") is legitimate

1) Summary of the Plaintiff Company’s assertion

A) Since all of the transfer proceeds of this case were paid in the business year 2000, all of the payment related to the transfer of the new construction business of this case should be included in the gross income for the business year 2000 of the Plaintiff company, and it cannot be included in the gross income for the business year 20

B) The transfer price of this case was not changed after the transfer of the new construction project, and the construction price of this case is actually included in the transfer price of this case.

C) Even if not, ○○ Construction paid KRW 700,107,484 out of the construction price of this case from May 23, 2000 to July 20, 200, and thereafter paid only the remainder of KRW 81,752,00 on January 20, 2001, the entire construction price of this case cannot be included in gross income for the business year 2001.

2) Determination

A) Only when the transfer price of this case was fully paid in the business year 2000, it cannot be deemed that the transfer price of the new construction project of this case should be included in the gross income for the business year 2000 of the Plaintiff company, regardless of whether the payment was made separately from the transfer price of the new construction project of this case. Thus, this part of the Plaintiff company’s assertion on different

B) In light of the following circumstances, the construction price of this case cannot be deemed as actually included in the transfer price of this case, and the fact that the transfer price of this case did not change after the transfer of the new construction project of this case does not affect such judgment. Thus, this part of the Plaintiff Company’s assertion is without merit.

① On May 19, 200, when transferring the new construction project of this case to ○○ Construction, the Plaintiff Company stated the total transfer price in the contract (Evidence B No. 12) as KRW 8.37 billion, which is the transfer price of this case (Article 2(1)) and agreed to settle the accounts after the actual inspection for KRW 2.87 billion, which is the transfer price for the subcontractor (Article 5).

② After that, ○○ Construction paid the Plaintiff Company a total sum of KRW 8.9 billion for the instant transfer price and the Plaintiff Company’s subcontractors, and paid the instant construction price separately to the subcontractors of the instant new construction project.

③ From June 2001 to October 20 of the same year, ○○ Construction requested the Plaintiff Company to issue a purchase tax invoice on the instant construction price, and accordingly, the Plaintiff Company issued a purchase tax invoice on the part of the instant construction price to ○○ Construction.

④ Although the director of the tax office requested the Plaintiff to vindicate whether the instant construction price was included in the instant transfer price prior to the instant disposition, the Plaintiff Company did not provide any explanation at the time.

⑤ Although the Plaintiff alleged in this case that “the instant construction cost was offset against the outstanding amount of the instant transfer price,” there is no evidence to acknowledge this.

C) In addition to the fact that ○○ Construction paid the instant construction cost over the business year from 2000 to 2001, as seen earlier, the liquidation of the remainder payment of the instant transfer price was completed in the business year of 2001, and the Plaintiff Company reported corporate tax for the year 2001, the instant transfer price included the instant transfer price in the gross income for the business year of 2001, the tax authorities held that the instant construction price may be included in the gross income for the business year of 2001, and the fact that ○ Construction paid part of the instant construction price for the business year of 2000, is insufficient to reverse this determination.

D) Therefore, the plaintiff company's arguments are without merit, and the disposition of this case does not contain any error as alleged by the above plaintiff.

4. Conclusion

Therefore, (1) The part of the plaintiff Kim Jong-su and Han-sung's action (the action on each disposition stated in 1.3, 7.7.), (2) the action against the defendant Lee Jong-ok's defendant 1 (the action on the disposition stated in 6. of claim) and the action against the defendant 1 (the action on the disposition stated in 4. of claim) against the defendant 1, 2007, the part of the claim for cancellation of the disposition of global income tax and the resident tax imposition, and (3) the part of the claim for cancellation of the notice of change of income (the action on the disposition stated in 8. of claim) against the defendant Dobong-gu's defendant 1, and the part of the claim for cancellation of the disposition of global income tax (the action on the disposition stated in 8. of claim) against the defendant 1, 2007 against the defendant 1, 207, and all of the claims are dismissed as it is so decided as per Disposition.