1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On April 20, 200, the Plaintiff registered the business as “B” with the trade name for the main purpose of installing steel structure (hereinafter referred to as “former B”). The former B discontinued the business under the name of “B” (hereinafter referred to as “former B”), and the former B discontinued the business ex officio on June 22, 2007.

B. On August 20, 2007, as the Plaintiff’s relative, the business registration was made for “B” (business registration number D; hereinafter “new B”) with the main purpose of installing steel structure in the name of “B” (business registration number D; hereinafter “new B”) under the name of the Plaintiff’s work as the employee in the former B, and the new B provided steel structure installation services, etc. to “E” (hereinafter “E”) from around that time to 2012.

C. As a result of the Seoul Regional Tax Office’s tax investigation into B and E (the principal customer of B), the actual business operator of the new B, who is not the registered owner C, deemed the Plaintiff to be the actual supplier of the services equivalent to KRW 12,211,081,47 during the value-added tax period from February 2, 2007 to February 2012 in the name of the Plaintiff, and notified the Defendant of the taxation data.

On August 4, 2014, the Defendant issued a total of 122,110,800 won of penalty tax pursuant to Article 22(1)2 of the former Value-Added Tax Act (amended by Act No. 11873, Jun. 7, 2013; hereinafter the same) on the ground that the Plaintiff was registered as a business operator in the name of another person C while operating the new B, and registered as a business operator in the name of another person C, from February 2, 2007 to February 2, 2012, against the Plaintiff, pursuant to Article 22(1)2 of the former Value-Added Tax Act (amended by Act No. 11873, Jun. 7, 2013).

(The detailed details are as shown in the attached list 1, hereinafter referred to as the "disposition of this case").

On March 23, 2015, the Plaintiff filed a petition with the Tax Tribunal for a trial seeking revocation of the instant disposition, but a decision to dismiss the Plaintiff’s petition was made on August 12, 2015.