1. The Defendant’s imposition of value-added tax of KRW 22,506,930 against the Plaintiff on June 27, 2014 is revoked.

2...

1. Details of the disposition;

A. On February 7, 2007, the Plaintiff’s dynamics B established C (hereinafter “C”) for the purpose of export and import of dental materials and wholesale and retail business.

The Plaintiff, a dentist, transferred KRW 4 million to B twice on February 7, 2007 and December 12, 2007. At that time, B paid 750 shares of C to the Plaintiff, and the Plaintiff was registered as C’s auditor on April 24, 2007.

B. The Defendant determined that C’s 50% (1,500 shares) of C’s 50% (1,500 shares) was an oligopolistic shareholder in accordance with the statement of changes in stocks, etc. submitted by C to the tax authority, and that C’s 20% (600 shares) was an oligopolistic shareholder. On July 16, 201, when C’s 201 notice was delinquent in corporate tax for 201, value-added tax for 201, 2012, and corporate tax for 2012, the Defendant notified C of the designation of the Plaintiff as the secondary taxpayer and the payment of KRW 58,8

C. When the value-added tax that was notified to C in 2012 was again defaulted, the Defendant, on June 27, 2014, notified C to designate the Plaintiff as the secondary taxpayer and to pay KRW 22,506,930.

(hereinafter “instant disposition”). The Plaintiff filed an objection with the Seoul Regional Tax Office on October 24, 2014, but was dismissed on October 24, 2014, and again filed an appeal with the Tax Tribunal, but was dismissed on April 13, 2015.

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

2. Whether the disposition is lawful;

A. On October 4, 2010, the Plaintiff asserted that the Plaintiff sold all of C’s shares to D, and resigned from C’s audit on June 30, 201. Since there is no actual fact in C’s management or control, the Plaintiff cannot become a secondary taxpayer of C.

(b) A corporation whose stocks are listed on a securities market prescribed by Presidential Decree under related Acts and subordinate statutes (amended by Act No. 12848, Dec. 23, 2014; hereinafter the same shall apply) and Article 39 of the Framework Act on National Taxes, shall be excluded;

(b).