1. On October 10, 2016, the Defendant imposed global income tax of KRW 82,370,710 on the Plaintiff for the year 2012.

1. Details of the disposition;

A. On November 25, 2011, to November 25, 2014, the Plaintiff was registered as the representative director of a stock company B (hereinafter “B”) who is engaged in tampet sales, sales agency, etc. on the corporate register.

B. During that period, the superintendent of the Yeongdeungpo District Tax Office calculated the amount of income as KRW 194,636,000 according to the method of estimated investigation and determination on August 2014 by which B did not report corporate tax in 2012, and determined and notified corporate tax as to B, and notified the Defendant of the taxation data after disposing of it as bonus to the Plaintiff who is the representative director of B.

Accordingly, on October 10, 2016, the Defendant notified the Plaintiff of the correction of KRW 82,370,710 as global income tax for the year 2012 (hereinafter “instant disposition”).

C. Accordingly, the Plaintiff filed an appeal with the Tax Tribunal by asserting that the instant disposition was unlawful, and the Tax Tribunal dismissed the appeal on August 8, 2017.

[Ground of recognition] Facts without dispute, Gap's 1, 2, 5, 6 evidence, Eul's 1 to 4, the purport of the whole pleadings

2. The plaintiff's assertion is not the actual B's representative, such as the plaintiff has no record of participation in the management of B.

3. Attached Form of the relevant Acts and subordinate statutes;

4. Determination

(a) Even if a person is registered as a representative director on the corporate register of the company, but he has not actually operated the company concerned, no comprehensive income tax shall be levied on such person by devolving any income of which the company is unknown;

On the other hand, since a person who is registered as a representative on the corporate register can be presumed to be actually operating the company, the representative on the corporate register must be proved by the party asserting that the representative on the corporate register actually failed to operate the company.

(see, e.g., Supreme Court Decision 2010Du18116, Dec. 23, 2010). B.

The evidence mentioned above and the statements stated in Gap evidence Nos. 3, 4, 7, and 8, and witness C's testimony are as follows.