1. Of the judgment of the court of first instance, 270,083 won in the imposition of global income tax of KRW 17,586,153 (including additional tax) for the year 2012.

(2) On December 1, 2015, the Plaintiff issued a notice of change in the amount of income, which was registered as the representative director of the instant company, to the effect that the Plaintiff would be disposed of by recognizing the Plaintiff as the representative director of the instant company at the time of the omission in filing a return and subtracting the expenses directly corresponding thereto.

C. On December 10, 2015, the instant company submitted to the Defendant a revised report on the performance of withholding tax amounting to KRW 390,767,573, and the amount of income tax paid to the Plaintiff was 69,768,350, but discontinued without paying the said amount.

On March 4, 2016, the Defendant imposed and notified the pertinent tax amount on the instant company, and revoked it on April 8, 2016, and on November 1, 2016, the Defendant issued a revised and notified the Plaintiff of the comprehensive income tax for each year from 2010 to 2014 as follows:

(hereinafter referred to as “instant disposition” in total). The amount of bonus disposition in the taxable year Nos. 12010 40,894,734 won 5,89,401 won 2201 27,430,430,091 won 2,837,103 won 32012 88,047,930 won 17,586,5830 won 17,586,153 won* 42013 137,462,791 won 35,960,822 won 52014 96,932,027 won 20,606, 191 won total 390,767,573 won,82,670 won,670 won

E. On January 17, 2017, the Plaintiff appealed and filed a request for examination with the National Tax Service, but the Commissioner of the National Tax Service dismissed the said request on September 27, 2017.

F. The statutes related to the disposition of this case are as shown in the attached Form “related statutes”.

【Ground of recognition】 The fact that there has been no dispute, Gap evidence 1, Eul evidence 1 through 4, and 22, the purport of all pleadings and arguments

2. The plaintiff's assertion that the company of this case was substantially operated is D, and the plaintiff lent only the name of the representative director. Thus, the disposition of this case on the premise that the plaintiff is the actual operator of the company of this case is unlawful.

3. Determination

A. Article 106(1)1 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 12, 2016) of the relevant legal doctrine is the amount included in gross income when the tax authority determines or revises the corporate tax base.