1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Details of the disposition

A Co., Ltd. (hereinafter “B”) was a corporation established on June 19, 195 with the construction business, etc. as its business purpose; and after completing business registration on June 20, 1995, it was closed on March 31, 2015 on the ground of a business depression.

At the time of the closure of business, the Plaintiff was holding 3,210 shares (27%) of the total number of shares issued by B as the representative director at the time of the closure of business.

B On December 30, 2016, the Defendant filed an after-term return of corporate tax for the business year 2015 to the Defendant, and the KRW 837,846,82 was included in the short-term loans of shareholders, executives, employees on the balance sheet in B.

The Defendant determined that the special relationship between the Plaintiff and the Plaintiff was extinguished at the time of the closure of the business, and on the ground that the said short-term loan was reverted to the Plaintiff as a result of the Plaintiff’s failure to recover the said short-term loan, the Defendant disposed of the said short-term loan amount of KRW 837,846,82 and the said short-term loan amount of KRW 11,023,175 as a bonus for the Plaintiff, and notified the Plaintiff of the change in the amount of income, which is the Plaintiff’s income attributed to the Plaintiff in 2015.

The Defendant did not report the global income tax on the amount of the change in the amount of income. On January 3, 2018, the Defendant determined and notified the Plaintiff of KRW 361,642,830 of the global income tax reverted to the year 2015.

(hereinafter “instant disposition”). On January 30, 2018, the Plaintiff dissatisfied with the instant disposition and filed a request for examination with the National Tax Service on June 19, 2018, but the said request for examination was dismissed on September 6, 2018.

[Grounds for recognition] The Plaintiff’s disposition of this case as to the lawfulness of the instant disposition of this case as to the following facts, Gap’s evidence Nos. 1, 2, and Eul’s evidence Nos. 1 through 6 (including those with serial numbers; hereinafter the same shall apply), the entire purport of the pleading, and the purport of the entire argument, should be revoked on the ground

The Plaintiff’s management becomes difficult.