1. The Defendant’s value-added tax amounting to KRW 48,457,760 and additional tax amounting to KRW 2,505,950 for the Plaintiff on June 17, 2014.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “instant company”) is a corporation that operated a housing construction business, etc. from around April 15, 199 to around March 10, 2014 while closing its business.

B. The number of shares issued by the instant company was 90,000 shares. From July 1, 2013 to March 7, 2014, C, the representative director of the instant company, was registered as holding 39,20 shares (49%) from July 1, 2013 to March 7, 2014, and the Plaintiff, C, as its children, was registered as holding 20,70 shares (25.8%; hereinafter “instant shares”). The corporate register of the instant company, the Plaintiff was registered as a director on July 1, 2013.

C. The instant company did not pay the total of KRW 197,53,90 for value added tax and additional tax for year 2013, value added tax for year 2014, KRW 51,402,180 for year 2014, and KRW 105,880,70 for earned income tax and additional tax for year 2013.

On June 17, 2014, when the assets of the instant company were unable to collect the amount in arrears, the Defendant deemed C and the Plaintiff to be an oligopolistic shareholder as of the date on which each of the above tax liability of the instant company was established pursuant to Article 39 subparag. 2 of the Framework Act on National Taxes, and designated C and the Plaintiff as the secondary taxpayer, and notified the Plaintiff to pay the Plaintiff the amount corresponding to the Plaintiff’s share out of the amount in arrears of the value-added tax for 2013, namely, value-added tax of 48,457,760,760, value-added tax of 2014, value-added tax of 13,261,760, value-added tax of 2014, value-added tax of 263,80, and additional tax of 26,063,253,400 (hereinafter “instant disposition”).

E. The Plaintiff dissatisfied with the instant disposition and filed an appeal on November 28, 2014, but the Tax Tribunal dismissed the Plaintiff’s appeal on March 25, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1-5, Gap evidence 3, 4, 7, 9, Eul evidence 1, and the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion is only a company operated independently by C, and only its shares and the name of its officer.