1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance concerning the instant case is as follows: (a) the court shall use “the same data” of the 9th 13th son of the judgment of the court of first instance as “the same data”; and (b) the 20th son’s “no brightness” as “no brightness”; and (c) the reasoning of the judgment of the court of first instance is as stated in the reasoning of the judgment, except for the addition of the judgment on the assertion that the plaintiff emphasizes in the court of first instance as follows, and thus, it shall be cited as it is in accordance with Article 8(2) of

2. Judgment on the plaintiff's assertion

A. Supreme Court Decision 201Du9935 Decided May 16, 2014 (hereinafter “Supreme Court Decision 2011Du9935 Decided May 16, 2014”) states, “The tax authority shall, in principle, assume the burden of proof as to the existence or absence of tax-related facts. This also applies to cases where the tax authority contests that the nominal business owner is different from the actual business owner, barring special circumstances, such as a separate legal provision converting the burden of proof. However, as long as the tax authority imposed tax by deeming the nominal business owner as the actual business owner, it is necessary to assert and prove that the nominal business owner subject to taxation differs from the actual business owner’s ownership. In such a case, the need for proof is sufficient if the judge has a reasonable doubt as to whether the actual business owner, such as the transaction, belongs to the nominal business owner, and if the judge becomes unable to have conviction, then the disadvantage therefrom is ultimately attributable to the tax authority bearing the ultimate burden of proof.” This case’s necessity or degree of proof required for the Plaintiff’s acquisition of real property, such as the Plaintiff’s construction of real property.