1. On May 11, 2015, the Defendant designated the Plaintiff as the secondary taxpayer and entered the list in the attached Table 1 against the Plaintiff.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “Nonindicted Company”) defaulted on May 11, 2015, totaling KRW 24,654,350 in total of the value-added tax for the period of KRW 1,654,350 in 2014 and the additional charges thereon, as indicated in the attached Table 1, KRW 2,181,880 in total, and KRW 6,780,90 in total of the business income tax for the year 2014 and the additional charges thereon.

(hereinafter “instant arrears”). B.

The Defendant: (a) on May 11, 2015, on the grounds that the Plaintiff was registered as holding 80% of the shares issued by the non-party company as indicated in the list below, the Defendant designated the Plaintiff as the secondary taxpayer of the non-party company and notified the Plaintiff of the total amount of KRW 21,468,960 including value-added tax equivalent to 80% of the amount in arrears of the instant case as indicated in the list No. 1 list, and the amount of KRW 5,902,090 including business income tax, etc.

(hereinafter referred to as "the Disposition in this case." The representative director of the plaintiff 4,000 shares and 80% C 1,000 shares 1,000 shares 20% of 20% of the shares of the number of shares.

C. On January 20, 2016, the Plaintiff dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal on January 20, 2016, but was dismissed on June 13, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1-1, 2-2, the purport of the whole pleadings

2. As a matter of course, the Defendant’s judgment on the main safety objection is based on the provisions of the National Tax Collection Act, since the additional dues under the National Tax Collection Act naturally accrue if the national tax is not paid by the due date, the portion corresponding to the additional dues among the dispositions in this case cannot be deemed a disposition subject to appeal litigation. However, the secondary tax liability for the additional dues of the principal taxpayer is finalized by the notice of imposition to the secondary taxpayer, and therefore the Defendant’s main safety objection is without merit.

3. Whether the instant disposition is lawful

A. The plaintiff's assertion is upon C's request that the auditor of the non-party company be assigned.