1. All of the instant lawsuits are dismissed.

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

1. Details of the disposition;

A. A. On June 5, 2015, the Plaintiff Company B, a representative director, (hereinafter “B”), was established on June 5, 2015 and engaged in the manufacturing of kitchen supplies, and was closed on September 30, 2016.

B. B did not pay any value-added tax of KRW 8,278,266, and value-added tax of KRW 22,377,570 for the first year of 2016.

C. On November 24, 2016, the Defendant notified, respectively, of KRW 8,278,266, and KRW 22,377,570, which was finalized on November 28, 2016, for each of the following reasons: (a) the Plaintiff, who is an oligopolistic shareholder B (100%), was designated as the secondary taxpayer for the amount of delinquent taxes; and (b) the Plaintiff was served on November 29, 2016, respectively.

On June 9, 2017, the Plaintiff filed a request with the Tax Tribunal for the revocation of the instant disposition, but the Tax Tribunal dismissed the Plaintiff’s request on October 11, 2017 on the ground that the period for request under Article 68 of the Framework Act on National Taxes has expired.

[Reasons for Recognition] Unsatisfy, Gap evidence 5 through 9 (including a provisional number; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the lawsuit of this case is lawful

A. Since the Plaintiff did not file a request for examination or adjudication within 90 days from the date of receipt of the instant notice of payment, the instant lawsuit is unlawful as it did not meet the requirements for an administrative appeal.

B. Article 55(1) of the Framework Act on National Taxes provides that “Any person whose rights or interests are infringed by either an illegal or unreasonable disposition or an absence of a necessary disposition under this Act or other tax-related Acts may file a request for an examination or a request for adjudication under the provisions of this Chapter to cancel or modify such disposition, or for a necessary disposition.” Article 56(2) of the Framework Act on National Taxes provides that “The administrative litigation against an unlawful disposition under Article 55 of the Administrative Litigation Act shall be