1. On January 11, 2018, the Defendant designated the Plaintiff as the secondary taxpayer of Company B, and against the Plaintiff.

1. Circumstances of each disposition of this case;

A. B Co., Ltd. (hereinafter “B”) is a corporation established for the purpose of soil construction business, reinforced concrete construction business, etc. on May 17, 2005, and was voluntarily closed on April 30, 2013. The value-added tax of KRW 92,783,210, and corporate tax of KRW 1,927,010 for the year 2012 is delinquent.

(b) The shares held by B from 2011 to 2013 are listed in the following table:

(C Co., Ltd. transferred all the shares held on September 30, 201 to the Plaintiff. The ratio of the number of shareholders in each year (%) shall be 40,500 100, Sept. 30, 201, Plaintiff 40,500, Sept. 30, 201, Plaintiff 40,500 100, Sept. 30, 2012, Plaintiff 40,500 100, 2013 Plaintiff 40,500, 2013

C. On January 11, 2018, the Defendant deemed the Plaintiff as an oligopolistic shareholder B, and thus, designated the Plaintiff as the secondary taxpayer. The Defendant imposed the imposition of value-added tax of KRW 92,783,210 for the second period of February 2012 on the Plaintiff, who was delinquent by B, and imposed the disposition of KRW 1,927,010 for corporate tax for the year 2012.

(hereinafter referred to as “each of the instant dispositions,” including the imposition of value-added tax and the imposition of corporate tax.

On February 6, 2018, the Plaintiff appealed to the Tax Tribunal for the revocation of each of the instant dispositions, but was dismissed on April 24, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 5, 6, 7, Eul evidence Nos. 1 through 3 (including each number; hereinafter the same shall apply) and the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The Plaintiff’s assertion that: (a) the Plaintiff lent B’s share acquisition fund to D, the representative director of B; and (b) as security, the Plaintiff is merely a shareholder in the form of title trust; and (c) is not a substantial shareholder; and (d) was transferred B’s share 20,000 shares to D on April 16, 2013, and is not an oligopolistic shareholder

Nevertheless, since the defendant made each of the dispositions of this case under different premise, each of the dispositions of this case must be revoked in an unlawful manner.

(b) Appendix attached to the relevant legislation;