1. The defendant shall pay KRW 97,692,820 to the plaintiff.

2. The plaintiff's remaining claims are dismissed.

3. Of the costs of lawsuit.

1. Basic facts

A. On July 1, 2015, the name of the Plaintiff was registered as an individual entrepreneur on July 1, 2015 under the name of the Plaintiff, and the report on business closure was made on June 30, 2016.

B. As of July 2, 2019, the Yongsan Tax Department confirmed that the Plaintiff’s delinquent value-added tax and global income tax amount of KRW 98,127,390 was the total amount of KRW 98,127,390. Of them, C-related tax amount is KRW 97,692,820.

[Ground of Recognition] Unstrifed Facts, Gap evidence 2 and 4 (including additional number)

2. Summary of the parties' arguments;

A. The summary of the plaintiff's assertion is that the plaintiff completed the business registration under the name of the plaintiff upon request of the defendant, who is the actual operator of C, and since the defendant agreed to settle the tax imposed by C, the defendant is obligated to pay to the plaintiff the amount equivalent to the tax imposed by C.

B. The gist of the defendant's assertion is that the defendant did not borrow the name in the name of the plaintiff and the tax should be paid by the plaintiff.

3. The following circumstances, which are acknowledged by comprehensively taking account of the overall purport of the pleadings in the written evidence Nos. 1 through 3, i.e., ① the business name of the Plaintiff was originally the Defendant, and the change to the Plaintiff was made on July 1, 2016, and as seen earlier, D prepared a confirmation document stating that he/she would lend his/her business name to the Defendant, ② the Plaintiff was paid benefits from C from November 2014 to March 2017, and the Plaintiff was recognized to have received benefits from March 2017, and corresponds to the Plaintiff’s assertion that he/she was only the employee of C; ③ the Plaintiff was continuously transferred money to the Defendant or Nonparty F on the Plaintiff’s passbook opened on August 2015 for the transaction with C; ④ the Defendant did not make any specific rebuttal on the above facts, upon request by the Defendant.