1. The plaintiff's lawsuit against the defendants is dismissed in entirety.

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

1. Details of the disposition;

A. From September 10, 2013 to November 8, 2013, the head of Yangcheon Tax Office conducted an investigation into the transaction order of value-added tax with respect to the Plaintiff, and confirmed that the Plaintiff filed a non-declaration of the tax invoice issued after registering the business of selective transfer business with the trade name B on July 18, 2011, and issued a non-declaration of the tax invoice on February 1, 2014 with respect to KRW 3,222,743,00 of the Plaintiff’s return of sale and KRW 872,236,880 of the Plaintiff’s return of purchase and KRW 63,157,896, KRW 139,80 of the year 2011, KRW 139,07,063 of the year 2012, KRW 24,274, KRW 934, KRW 2013, KRW 3687,798 of the Value-Added Tax Act.

(hereinafter referred to as “instant disposition imposing surtax”);

B. On February 4, 2014, based on the result of the above tax investigation, the head of the Defendant Kimpo-si respectively notified the Plaintiff of KRW 57,191,217 of the global income tax for the year 201 and KRW 443,224,756 of the global income tax for the year 2012.

(hereinafter “instant disposition of imposition of global income tax”. The instant disposition of imposition of global income tax and the instant disposition of imposition of global income tax in the entirety of the instant disposition of imposition of global income tax

C. On May 29, 2015, the Plaintiff filed a petition for review with the National Tax Service on the grounds that the appeal period has expired. However, the Plaintiff was dismissed on June 5, 2015.

On May 27, 2015, a request for examination was filed with the National Tax Service on the instant disposition of comprehensive acquisition tax, but a decision of rejection was made on June 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 3 (including branch numbers for those with additional numbers; hereinafter the same shall apply), Eul evidence 1, Eul evidence 1, Eul evidence 1, and the purport of whole pleadings

2. Whether the lawsuit of this case is lawful

A. Article 56(2) and (3) of the Framework Act on National Taxes provides that “Any administrative litigation against any illegal disposition under the Framework Act on National Taxes or any tax-related Act shall be filed within 90 days from the date on which a request for evaluation or adjudgment under the Framework Act on National Taxes and a decision thereon is notified,” and Article 61