Whether the designation of the secondary taxpayer is legitimate

As of the date of establishing the liability for tax payment to a corporation, the fact that the plaintiffs' shares were transferred to others is not objectively verified, so the designation of the secondary liability for tax payment and the notice for payment are legitimate.

Article 39 (Secondary Tax Liability of Investors)

All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

Compared with the records of this case and the judgment of the court below, the assertion of the grounds for appeal by appellant is not accepted in accordance with Article 4 of the Act on Special Cases concerning the Procedure for Appeal.

Therefore, all appeals are dismissed in accordance with Article 5 of the Act, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.