1. On March 26, 2016, the Defendant’s additional tax on negligent tax returns of KRW 283,714,690, global income tax for the year 2010 owed to the Plaintiff.

Basic Facts

B Co., Ltd. (hereinafter “B”) established electrical construction business, etc. on August 28, 200 as its business objective, and closed its business on August 9, 201.

From the incorporation of B to April 12, 2001, the Plaintiff alone and jointly with C from the next day to February 17, 2003. From the next day to November 24, 2009, the Plaintiff was registered as the representative director of B, respectively, jointly with D from the next day to the closing day of business.

(A) On February 20, 2012, the Defendant issued a notice of the decision to revise corporate tax to include the above short-term loans in the tax base of corporate tax (income) in B in the business year 2010, on the ground that “B closed its business on August 9, 2011, and omitted the report on short-term loans 59,876,000 won (hereinafter “instant short-term loans”) that were not recovered in the business year 2010, and notified the change in the amount of income to be disposed of as bonus to the Plaintiff, who is the B’s representative.

On March 26, 2016, the Plaintiff did not report the labor income tax following the notice of change in the above amount of income. On March 26, 2016, the Defendant issued a notice of decision of correction imposing global income tax of KRW 283,714,690 (including additional tax on negligent tax returns of KRW 18,827,037, additional tax on negligent tax, and KRW 77,117,290) for the year 2010 (hereinafter “instant disposition”).

(A) On April 11, 2016, the Plaintiff filed an appeal seeking revocation of the instant disposition, and the Tax Tribunal dismissed the said appeal on July 21, 2016.

(A) 【No. 12’s ground for recognition” did not have any dispute, Gap evidence 1, Eul evidence 6, Eul evidence 12, Eul evidence 12, Eul’s assertion of the purport of the whole pleadings, and Eul’s assertion of the purport of the whole pleadings, and the plaintiff’s assertion of judgment in the business year 2010 where the plaintiff did not recover the short-term loans of this case from Eul, the plaintiff was the representative director in the name of Eul who was awarded a subcontract for some construction works from Eul, and the actual representative of Eul is the plaintiff’s external third village C, and the affairs