1. Of the instant lawsuit, the part seeking revocation of the disposition imposing KRW 3,995,570, which is the sum of the surcharge and increased surcharge.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “instant corporation”) was a corporation established on October 5, 2004 for the purposes of the construction business and the civil engineering business, and was delinquent in the amount of KRW 7,958,670 in value-added tax in 2007, corporate tax of KRW 4,478,780 in 207 (excluding each additional charge and increased additional charge).

B. As of December 31, 2007, shareholders listed in the list of shareholders of the instant corporation are as follows:

(hereinafter the Plaintiff’s shares (hereinafter “instant shares”). Name CD E E’s other directors’ 20,400 6,600 5,6000 4,000 4,000 40,000 40,000 40,000 51.0 0.0 October 14, 100 10.0 10.00 10.0

C. The Defendant, at the time of 2007, designated the Plaintiff as the secondary taxpayer pursuant to Article 39(1) of the former Framework Act on National Taxes (amended by Act No. 11124, Dec. 31, 201; hereinafter “the Act”) on the ground that the Plaintiff actually exercised the rights to shares owned in excess of 50% of the shares of the instant corporation, and notified the Plaintiff of the payment of value-added tax 6,615,790 (this tax amount is KRW 4,058,920, KRW 2,56,890), corporate tax 207, KRW 3,72,850 (this tax amount is KRW 2,284,170, KRW 170, increased additional dues, and KRW 1,48,386,68,00).

The plaintiff appealed against this and filed an appeal, but was dismissed by the Tax Tribunal on December 18, 2013.

[인정근거] 다툼 없는 사실, 갑 제1 내지 6호증, 을 제1호증의 1, 2, 을 제2호증의 각 기재, 변론 전체의 취지 [근거법령] ▣ 구 국세기본법(2011. 12. 31. 법률 제11124호로 개정되기 전의 것) 제39조(출자자의 제2차 납세의무) ① 법인(주식을 「자본시장과 금융투자업에 관한 법률」 제9조 제13항 제1호에 따른 유가증권시장에 상장한 법인은 제외한다. 이하 이 조에서 같다)의 재산으로 그 법인에 부과되거나 그 법인이 납부할...