1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

The reasons why the court should explain concerning this case are the same as the reasons for the judgment of the court of first instance except for the following modifications. Thus, this case is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Generally, the burden of proving the facts of taxation requirements in a lawsuit seeking revocation of disposition imposing tax should be borne by the imposing authority. However, if the facts alleged in light of the empirical rule in the course of a specific lawsuit are revealed, it cannot be readily concluded that the pertinent taxation disposition is an unlawful disposition that failed to meet the taxation requirements unless the pertinent facts are proven (see, e.g., Supreme Court Decision 2006Du6604, Feb. 22, 2007). In light of the language and text of the subcontract agreement and settlement agreement between the Plaintiff and Tae Taeho comprehensive Construction submitted in the course of a field investigation, it is reasonable to view “the amount payable prior to the contract for construction, 1,673, 878,50 won” as the amount equivalent to the existing debt amount of Taeho comprehensive Construction. However, the witness C applied by the Plaintiff at the trial again to the effect that “the aforementioned testimony is insufficient to the effect that the witness’s testimony was made on behalf of the witness at the construction site” (see, e.g., see the above 2 testimony construction agreement., the witness at the above. testimony.