1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From August 25, 2009 to March 5, 2014, the Plaintiff was registered as a business entity of Sungnam-si Branched building B and D having a place of business under subparagraph C (hereinafter “instant place of business”).

B. The Defendant imposed a total of KRW 144,878,950 (hereinafter “instant disposition”) on the Plaintiff on the ground that the Plaintiff filed a non-report of value-added tax related to the instant business establishment as shown in the attached Form.

[Reasons for Recognition] Facts without dispute, entry in Eul evidence Nos. 1, 2, and 3 (including each number; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The gist of the Plaintiff’s assertion is that the Plaintiff served in the company or attended the university during the period from August 25, 2009 to March 5, 2014) during which the pertinent disposition belongs (from August 25, 2009 to March 5, 2014), and the Plaintiff’s father was unaware of the Plaintiff’s operation of the instant place of business under his name, and there was no document related to the instant disposition, such as tax payment notice, etc., received from the Defendant.

Therefore, in accordance with the substance over form principle, taxes on the instant workplace should be imposed on the Plaintiff’s father, not on the Plaintiff’s father, and the instant disposition is null and void.

B. 1) Determination 1) In an administrative litigation seeking the invalidity of an administrative disposition regarding each of the instant dispositions by asserting the lawful delivery of each of the instant dispositions and seeking the invalidity of such administrative disposition, the Plaintiff is liable to assert and prove that the administrative disposition is null and void, and the service of a tax notice is provided to the domicile, temporary domicile, residence, or office pursuant to Article 8(1) of the Framework Act on National Taxes, except in extenuating circumstances. In such cases, if the person to receive the service is not present at the place, the service may be provided to the employee and other employees or a person living together with the mental capacity to make reasonable judgment (see, e.g., Supreme Court Decision 2009Du3460, May 13,