1. The plaintiff's lawsuit against the director of the branch office of the tax office shall be dismissed in entirety.

2. Defendant Republic of Korea shall pay to the Plaintiff 86,922.

1. Details of the instant case

A. On April 10, 2013, the Plaintiff filed an application for grievance with the purport that the Plaintiff would cancel the value-added tax imposed on the Plaintiff, as it is not an actual business operator of the lease business for the C-dong 403 of the building C-dong, Seongbuk-gu, Sungnam-si, which was operated under the name of the Plaintiff from August 1, 2004.

B. On April 22, 2013, the director of the tax office having jurisdiction over the branch office of the party shall decide to revoke the value-added tax imposed on the Plaintiff by deeming the Plaintiff’s grievance to be reasonable, and notify the Plaintiff thereof. On May 10, 2013, the name of the actual business operator of the instant case was changed from the Plaintiff to C.

C. On October 18, 2013, the Plaintiff filed an application for refund of KRW 86,922,710, including value-added tax related to the instant business with the head of a regional tax office having jurisdiction over the Defendant branch office, but the Plaintiff did not comply with the request by the head of the regional tax office on January 17, 2014, and filed an objection with the Central Tax Tribunal on February 10, 2014, which was dismissed in entirety.

[Ground of recognition] Unsatisfy, Gap evidence Nos. 1 through 3, 9, 10 (including paper numbers; hereinafter the same shall apply)

2. The provisions pertaining to the determination of the determination of the national tax refund as to the lawsuit against the defendant of the branch office of branch office are not only the internal administrative procedure for the refund of a national tax for which the tax payer's claim for repayment has already been determined, but also the claim for repayment is not finalized only by the determination of the national tax refund under the above provision. Thus, the determination of the national tax refund or the refusal of refund as to the application for this determination is not a disposition that specifically and directly affects the existence or scope of the tax payer's claim

(see, e.g., Supreme Court en banc Decision 88Nu6436, Jun. 15, 1989; Supreme Court Decision 2007Du4018, Nov. 26, 2009). Accordingly, all lawsuits against the chief of a tax office having jurisdiction over the defendant's branch office are brought.