Whether the assertion that the actual business operator is different is legitimate or not.

It is reasonable to see that the instant disposition is legitimate because it is not merely lending the name, but is a business operator or a business operator who actually participated in the operation of the instant business establishment.

Article 2 of the Value-Added Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

Although all of the records of this case and the judgment of the court below and the grounds of appeal were examined, since the assertion on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal, it is clear that the appeal is dismissed under Article 5 of the same Act, and it is so decided as per