1. On March 5, 2013, the Defendant imposed an imposition of global income tax of KRW 98,366,870 (including additional taxes) on the Plaintiff in 2008.

1. Details of the disposition;

A. From July 25, 2007 to October 30, 2008, the Plaintiff was registered as the representative director on the corporate register of a limited liability company C (B) that engaged in alcoholic beverage wholesale business in Gangdong-gu Seoul Metropolitan Government (B).

B. Around June 2009, the director of the Seoul Regional Tax Office: (a) sold non-data of KRW 352,270,546 from the second half of 207 to the second half of 2008; (b) appropriated the purchase amount of KRW 67,360,00 in excess of the purchase amount of KRW 67,360.0; (c) notified C of the second half of 2007 value-added tax (including additional tax); (d) KRW 20,194,150 (including additional tax); (d) value-added tax of KRW 20,194,150 for the first half of 208; (e) value-added tax of KRW 47,391,09 (including additional tax); and (e) corporate tax of KRW 62,916,630 for the business year 208; and (e) notified the Defendant of KRW 205,297,297,29708; and (g.94.7.7.208)

C. Accordingly, on March 5, 2013, the Defendant issued a correction notice (hereinafter “instant disposition”) on global income tax of KRW 98,366,870 (including additional tax) according to the bonus disposition to the Plaintiff in 2008.

The Plaintiff appealed and filed an objection on June 27, 2013, but was dismissed by the Defendant on July 25, 2013.

In other words, the Plaintiff filed a request for review on October 28, 2013, but received a decision of dismissal from the National Tax Service on December 31, 2013.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 to 7, and 10 (including provisional number), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion C is F, and F transferred C to G on July 19, 2007. At this time, the Plaintiff retired from C.

Since July 19, 2007, C's actual manager is the actual manager.