1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. From June 1, 2002, the Plaintiff: (a) established Company B on January 19, 2010, and registered as a corporate proprietor on January 21, 2010 (the location of business: Kucheon-gun, Kucheon-gun, Kucheon-gun, Kucheon-si: hereinafter “instant corporate proprietor”).

B. On January 28, 2010, the Plaintiff agreed to lend the name of the instant individual business operator to D, and reported correction of the personal business registration of the instant case, and corrected the trade name from “B” to “E” to “E”, and the location of the business place from “Gangcheon-gun Hongcheon-gun F, Geumcheon-gun, Kuwon” to “Gangwon Hongcheon-gun, Hongcheon-gun, Kuwon,” added the type of business (bak and rice culture business), and D operated the business added by using the name of the instant individual business operator

The history of correction of business registration of the instant individual business operator is as shown in the attached Table.

C. From 1st to 2010, the Plaintiff filed a value-added tax return by adding each revenue amount of the instant individual proprietor’s retail business and the bread manufacturing business to the 2nd taxable period of the value-added tax in 2010.

The director of the competent tax office obtained information that D would engage in processing transactions in the name of the instant individual entrepreneur, and conducted a trade order-related investigation for the year 2010 and the taxable period 2011 from January 16, 2012 to April 5, 2012. After January 28, 2010, the head of the competent tax office retroactively cancelled the business registration of the instant individual entrepreneur by deeming that D had no actual existence of the instant individual entrepreneur’s business.

① In addition, the Defendant determined that the instant individual entrepreneur’s sales amount of KRW 82,057,629, the purchase amount of KRW 121,393,832 related to the beverage retail business was a disguised transaction attributable to the pertinent corporate entrepreneur, and notified the Defendant of the taxation data. ② The Plaintiff filed a criminal charge against the violation of the Punishment of Tax Evaders Act, etc., and the Chuncheon District Court in criminal trials following the accusation.