A. B Co., Ltd. (hereinafter “instant company”) filed a corporate tax return on March 31, 2010 on March 2009, but did not pay the said tax amount.

B. On May 4, 2010 and July 5, 2010, the Defendant issued a notice of payment of the above corporate tax to the instant company, but the instant company failed to pay it. On October 31, 2013, the Defendant deemed the Plaintiff as an oligopolistic shareholder and issued a notice of designation of the secondary taxpayer and issued a notice of payment of corporate tax of KRW 23,626,70 according to the Plaintiff’s equity ratio.

(hereinafter referred to as “the first disposition of imposition”). (c)

On March 3, 2014, the Plaintiff filed an objection against the initial disposition of imposition on the ground that “the Plaintiff transferred all of the shares of the instant company owned by it to C on July 28, 2010, and at the time C agreed to accept all the obligations of the instant company.” The Defendant deemed the Plaintiff’s objection justifiable on March 7, 2014, and revoked the initial disposition ex officio.

After that, on November 18, 2014, the Defendant designated the Plaintiff as the secondary taxpayer and notified the payment of corporate tax of KRW 23,626,770 according to the Plaintiff’s share ratio on the ground that “the Plaintiff transferred the instant company shares on July 28, 2010, but corporate tax for the business year 2009 was already established prior to the date of the Plaintiff’s share transfer.”

(hereinafter “instant disposition”) e.

On February 13, 2015, the Plaintiff dissatisfied with the instant disposition and filed a request for examination with the Commissioner of the National Tax Service, but the Commissioner of the National Tax Service dismissed the Plaintiff’s request for examination on April 10, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 7, Eul evidence No. 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion ① Although the defendant revoked ex officio the initial disposition based on the plaintiff's objection, the defendant also made the disposition of this case against the principle of trust and good faith of the country. The disposition of this case is unlawful.

② On July 28, 2010, the Plaintiff himself.