1. The Defendant shall pay to the Plaintiff KRW 99,364,560 and the interest rate of KRW 20% per annum from June 29, 2013 to the day of complete payment.

1. Facts of recognition;

A. The Plaintiff’s father, the father of the Plaintiff (the Deceased, Apr. 20, 2008, hereinafter referred to as the “Death”) conducted a stone and artificial aggregate business with the Plaintiff’s trade name “C” from February 6, 2003 to October 16, 2006.

B. Around May 2007, the Defendant imposed tax on the Plaintiff, the nominal owner, on global income tax and value-added tax arising in relation to the deceased’s business during the pertinent business period, and seized the Plaintiff’s benefit claim.

C. From June 22, 2007 to November 27, 2012, the Defendant collected KRW 9,364,560 from the Plaintiff’s wage claim.

On November 20, 2012, the Plaintiff lent the name of the business operator to the Samsung Tax & Family Protection Office, and the Plaintiff’s actual business was the father, who is the deceased, and accordingly, submitted a grievance application for cancellation of the taxation disposition for himself.

E. On December 26, 2012, the head of Samsung District Tax Office notified the Plaintiff that the Plaintiff’s civil petition for grievance was accepted, and released the attachment on January 2, 2013.

[Ground of recognition] Unsatisfy, entry of Gap evidence 1 through 22, each of the taxation information submission orders by this court, the purport of the whole pleadings

2. Determination

A. According to the above facts finding as to the cause of the claim, the Defendant is obligated to pay the Plaintiff KRW 99,364,560, and damages for delay collected from the Plaintiff, except in extenuating circumstances.

B. The Defendant’s assertion that the disposition of imposition was revoked only for the part in arrears at the time when the Plaintiff’s civil petition for grievance was filed, but the following circumstances acknowledged by the above facts and the evidence revealed earlier, the Plaintiff’s purport of the application for civil petition for grievance appears to have sought revocation of the entire tax disposition imposed on the Plaintiff. ② The Defendant did not indicate that partial revocation was revoked when the attachment was revoked on the ground that the disposition was revoked, and ③ the grounds for refusal of refund presented