1. All of the instant lawsuits are dismissed.

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

1. Basic facts

A. C Co., Ltd. (hereinafter “Nonindicted Company”) did not pay KRW 47,348,580 in total amount of value-added tax for the second period from 201 to 2012 and corporate tax for the business year from 2012 while engaging in general waste transport and disposal business in Seongbuk-gu, Seongbuk-gu, Seoul.

B. As of October 16, 2013, the Defendant: (a) designated the Plaintiffs as shareholders holding 50% each of their shares in the register of shareholders of the non-party company as secondary taxpayers (major shareholders); (b) imposed the Plaintiffs each of the value-added tax for the second period of 201, 129,140, 8,792,550, and 776,000, 2,113,690, 690, and 5,805,170, and 4,057,740, respectively, of the value-added tax for the second period of 2012, respectively; and (c) imposed and notified the Plaintiffs each of the value-added tax for the second period of 2012.

C. The Plaintiffs were dissatisfied with each of the above taxation dispositions and requested for adjudication to the Tax Tribunal, but all of the aforementioned claims were dismissed on June 30, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 2-1, Eul evidence 1-2, Eul evidence 1-2, Eul evidence 4, the purport of the whole pleadings

2. Determination on this safety defense

A. The defendant asserts that the plaintiffs' assertion was merely a shareholder in the name of the non-party company and did not actually exercise the rights as a shareholder, and that the second taxpayer did not constitute an oligopolistic shareholder, and that the plaintiff filed the lawsuit in this case only after the lapse of 90 days from the date when the plaintiffs were notified of the decision of the Tax Tribunal on each of the above taxation, and that the lawsuit in this case is unlawful because the period of filing the lawsuit in this case is excessive.

B. 1) According to Article 56 of the Framework Act on National Taxes, an administrative litigation against an illegal disposition, which is a disposition under the Framework Act on National Taxes, may not be filed without going through a request for evaluation or a request for adjudication under the Framework Act on National Taxes and a decision thereon (Article 56 (2)).