1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff is the largest shareholder who holds a registered director of B Co., Ltd. (the date of incorporation, August 31, 2012; March 25, 2014; hereinafter “Nonindicted Company”) and a 55% share of 55% (hereinafter “Nonindicted Company”).

However, the Plaintiff borrowed the amount equivalent to the capital from the non-party company C at the time of incorporation, and paid the loan to the above lending company immediately after its incorporation.

B. On July 15, 2013, when reporting the corporate tax base for the business year of 2012, the first business year, Nonparty Company reported the provisional payment of KRW 191,00,000 and the accrued interest of KRW 3,357,90.

C. On October 16, 2017, the Defendant disposed of the Plaintiff on the ground that “the special relationship between the Nonparty and the Plaintiff was annulledd on March 25, 2014, which was the date of closedown.” Therefore, the Defendant issued a revised notice of KRW 191,00,00, recognized interest KRW 3,032,975 (hereinafter “instant provisional payment”) to the Plaintiff according to the share ratio of the Plaintiff, 106,718,136 won (= [191,00,000 won 3,032,975 won) x 55%] to the Plaintiff, and issued a revised notice of KRW 28,486,050 (including additional taxes) for global income tax for the year 2014.”

(hereinafter “instant disposition”) D.

On January 2, 2018, the Plaintiff filed an administrative appeal with the Tax Tribunal. However, the judgment dismissing the Plaintiff’s claim was rendered on June 29, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 5, 14, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion that the provisional payment of this case occurred at the time of the establishment of the non-party company, and the non-party company did not have any substantial economic activity. The non-party company should be deemed to have been liquidated immediately, and in such case, the non-party company’s obligation to return the investment to the Plaintiff by the non-party company and the Plaintiff’s provisional payment obligation under Article 11 subparag. 2(a) of the Enforcement Decree of the Corporate Tax Act and Article 6-2 subparag. 3 of the Enforcement Rule