1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. A. A Incorporated Agricultural Company B (hereinafter “B”) is a corporation established for the purpose of distributing, processing, selling, etc. agricultural products, and the total amount of KRW 25,093,570 for local income tax (pro rata corporate tax) reverted to year 2013 was delinquent.

B. At the time when B’s liability for tax payment was established, the Defendant deemed that the Plaintiff’s shares exceeding 50% of the shares issued by B (hereinafter “instant shares”) were oligopolistic shareholders, and determined and notified the Plaintiff of KRW 22,584,190 equivalent to the Plaintiff’s share ratio (90%) of the local income tax in arrears (90%) on May 18, 2015, after designating the Plaintiff as the secondary taxpayer with respect to the said delinquent tax amount.

(hereinafter “instant disposition”). C.

On October 26, 2015, the Plaintiff filed an objection against the instant disposition, and filed an appeal with the Director of the Tax Tribunal on October 26, 2015, but the appeal was dismissed on December 29, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1, Gap evidence 3, Eul evidence 2, Eul evidence 3 and the purport of whole pleadings

2. Whether the instant disposition is lawful

A. The summary of the Plaintiff’s assertion is that the Plaintiff only lent the name to C upon the request of the representative director C, and only was registered as a shareholder in the register of shareholders, and there was no actual involvement in the operation of B. Thus, the instant disposition based on the premise that the Plaintiff is a beneficial shareholder is unlawful.

(b) as shown in the attached Form of the relevant statutes;

C. Determination of whether it constitutes an oligopolistic shareholder under Article 39(2) of the Framework Act on National Taxes is a member of a group which owns 51/100 or more of the shares in a special relationship, and it does not need to be a person who actually controls the management of a corporation by participating in the management of the corporation, or who actually exercises the rights to 51/10 or more of the total number of shares issued by the corporation concerned.

On the other hand, the ownership of shares is a list of shareholders, a statement of stock transfer or a register of shareholders.