1. The instant lawsuit shall be dismissed.

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

1. Basic facts

A. On April 4, 2011, the Plaintiff registered a motor vehicle trading business under the trade name “C” with Pyeongtaek-si B No. 1 located at the place of business, and on February 10, 2012, on which the said place of business was located, the Plaintiff filed a report on the correction of the business registration with Pyeongtaek-si D No. 22 and 23 (hereinafter “instant place of business”).

B. After closing the instant place of business on March 15, 2016, the Plaintiff filed a final return on the value-added tax for the first term portion on April 19, 2016 with the Defendant on April 19, 2016, and filed a final return on the amount of value-added tax for the first term portion in 2016, the Plaintiff filed a return on the amount of tax payable at KRW 10,950,634, the amount of tax calculated by deducting each of the input tax amount of KRW 10,950,634, the deducted tax amount of KRW 88,920,

C. However, as the Plaintiff did not pay the above tax amount, the Defendant rendered a decision on June 1, 2016 on the collection notice of KRW 18,763,171 (including additional tax) against the Plaintiff (hereinafter “instant collection notice”). D.

On October 21, 2016, the Plaintiff filed an application for rectification with the Defendant on the ground that the Plaintiff only lent the name of business registration and that the Plaintiff was not a person liable for duty payment, but withdrawn the said application on December 16, 2016.

【Ground of recognition】 The fact that there has been no dispute, entry of Eul Nos. 1, 2, 4, 5, and 6 (including paper numbers), the purport of the whole pleadings

2. Whether the lawsuit of this case is lawful

A. The plaintiff asserted that the notice of collection in this case against the plaintiff, who is not the actual owner of income, etc. subject to taxation, is unlawful as violating the principle of substantial taxation under Article 14 of the Framework Act on National Taxes.

The defendant asserts that the lawsuit of this case is unlawful as it was filed without going through the prior trial procedure under the Framework Act on National Taxes.

B. According to Articles 55, 56(2), 61(1), and 68(1) of the Framework Act on National Taxes, national taxes shall be disposed of.