1. Of the judgment of the court of first instance, the part against the plaintiff falling under the order to revoke below shall be revoked.

1. The reasoning of this court concerning this part of the disposition is as follows: (a) except for the case where the second part of the second part of the judgment of the court of first instance (hereinafter “instant company”) is deemed to be the part of the 2nd to 8th part of the judgment of the court of first instance, i.e., the pertinent part of the judgment of the court of first instance, i.e., the 8th to 2nd, i., i.e., the 1st part of the disposition; and (b) the part of the 2nd part of the judgment of the court of first instance

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) that the Plaintiff did not take over the instant business refers to the acquisition by the transferee of the human and physical facilities of the business and the change of the management owner as it is. In the instant case, around 2008, the instant company had already discontinued its business and there was no business to be transferred to the Plaintiff. In this case, the instant company merely changed the name of the building permit from the instant company to the Plaintiff, and thus, it cannot be deemed the transfer or acquisition of the business. Nevertheless, the Defendant rendered the instant disposition by deeming the Plaintiff as the secondary taxpayer of the instant company, which was unlawful. 2) The instant company asserted that the Plaintiff did not take over the instant business, was in a de facto closed condition after bankruptcy, and there was no price for the Plaintiff’s transfer or acquisition by transfer exceeding the assets.

Therefore, in the case of comprehensive transfer and acquisition of business, it cannot be deemed that the secondary tax liability is established under the premise that the transferee may impose the transferor’s tax on the transferee within the scope of the amount of the transfer price paid to the transferor.

3. The Plaintiff’s claim that the scope of liability is limited, even if the Plaintiff is liable for secondary tax payment, the principal tax, additional tax, and additional dues for which the Plaintiff’s tax liability becomes final and conclusive by July 17, 2013, which could be deemed to have taken over the instant business from the instant company, even if the Plaintiff had the secondary tax liability.