1. The Defendant’s global income tax amounting to KRW 454,792,660 (including additional tax) for the Plaintiff on November 1, 2014.

1. Details of the disposition;

A. On January 10, 2011, the Plaintiff: (a) as “B”; (b) as “B”; (c) the opening date of the business; (d) as “10 January 10, 201; (b) as “Seoul Mapo-gu Buildings 401, the location of the business; (c) the type of the business, which is its domicile; and (d) the retail/electronic commerce business, (e) completed the business registration after completing the business registration; and (e) closed on September 30, 201.

B. On May 31, 2012, the Plaintiff filed a return on and paid the global income tax for the year 2011 on the basis of 2,988,083,229 won, and 2,962,434,753 won by appropriating the amount of income from the instant business as KRW 25,648,476, and the amount of business income from the business of self-supporting artists, etc., calculated as KRW 360,690.

C. The Defendant requested the Plaintiff to submit relevant books and data regarding KRW 2,820,049,00, which was not submitted with the receipts of qualified evidence among the necessary expenses for the instant business reported as simple books, but the Plaintiff did not submit them.

On November 1, 2014, the Defendant estimated the business income related to the instant business, and notified the Plaintiff of the rectification of the global income tax of KRW 491,33,580 (including the additional tax) that reverts to the year 2011.

On January 6, 2015, the Defendant corrected the amount of 36,540,920 of the above amount of tax by reducing the amount of tax on the ground that the error in the calculation of the amount of tax was corrected.

[hereinafter] The disposition of imposition of global income tax of 454,792,660 won (including additional tax) for the 2011 revised as above is 'the disposition of this case'

(e) Meanwhile, although the Plaintiff filed a petition for trial on December 17, 2014, the Tax Tribunal rendered a decision to dismiss the Plaintiff’s petition for trial on March 19, 2015. [Grounds for recognition] The fact that there is no dispute, Gap’s 1, 2, and 4, Eul’s 1, 2, 9, and 10 evidence (including the pertinent number), and the purport of the entire pleadings.

2. Whether the instant disposition is lawful

A. Article 14(1) of the Framework Act on National Taxes provides that if the ownership of the income, profit, property, act or transaction subject to taxation is merely nominal, and there is another person to whom such income, profit, property, act or transaction belongs.