1. On February 6, 2016, the Defendant imposed value-added tax of KRW 15,753,620 on the Plaintiff for the second term of 2012.

1. Details of the disposition;

A. A. A Co., Ltd. (hereinafter “corporation in arrears”) was established on May 14, 2012 and engaged in the maintenance and management business of business facilities as its main business, but was closed on June 30, 2015, and was in arrears with value-added tax of KRW 15,753,620 for the second term period of 20 years in 2012.

B. On February 6, 2016, the Defendant: (a) deemed that the Plaintiff’s shares at the time when the liability for tax payment was established constituted constituted 100% of the total issued shares (1,000 shares); (b) designated the Plaintiff as the secondary taxpayer and imposed and collected KRW 15,753,620 on the Plaintiff’s secondary taxpayer.

(hereinafter “instant disposition”). C.

The Plaintiff appealed and filed an objection on March 7, 2016, but was dismissed on April 25, 2016. On September 13, 2016, the Tax Tribunal rendered a decision to re-examine on December 22, 2016 that “the instant disposition was an oligopolistic shareholder of the delinquent corporation and corrected according to the result of re-audit.”

The Defendant conducted a reinvestigation from January 24, 2017 to February 12, 2017, and notified the Plaintiff that the initial disposition was justifiable on February 23, 2017. The Plaintiff received it on March 3, 2017.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1 through 5 (including branch numbers, hereinafter the same shall apply), Eul evidence No. 1, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The defendant asserts that the disposition of this case is legitimate in light of the grounds for disposition and relevant statutes.

As to this, the Plaintiff is against the binding force of the decision of the Tax Tribunal on re-audit, and ② The Plaintiff, not a substantial shareholder of the delinquent corporation, has stolen the name of the shareholder or has lent the name of the shareholder, and the substantial shareholder is C, so the instant disposition is unlawful.

B. Article 39 of the former Framework Act on National Taxes (amended by Act No. 11845, May 28, 2013) is the second investor.