1. Of the instant lawsuit, the Defendant’s principal tax out of KRW 7,324,90,00 for the second period of value-added tax for the Plaintiff on March 7, 2014.

1. Details of the disposition;

A. On February 21, 2013, the Plaintiff transferred the business registration of sports equipment and the retail store of golf products in the trade name, “C” from 113 to 115, Gangnam-gu Seoul, Seoul (hereinafter “B place of business”), and on April 2, 2014, B place of business, Seoul Seocho-gu, to 103 (hereinafter “D place of business”).

B. On March 7, 2014, the Plaintiff filed a final return on the second taxable period of value-added tax in 2013 with respect to the Plaintiff’s business establishment, and the Defendant did not pay the said tax amount. On March 7, 2014, the Defendant issued a payment notice (including additional tax for arrears 84,710 won) to the Plaintiff (hereinafter “instant payment notice”).

C. In addition, on April 1, 2014, the Defendant decided and notified the Plaintiff of KRW 3,620,000 of the value-added tax of KRW 1st, 2014.

(hereinafter referred to as "the instant disposition") d.

The Plaintiff, dissatisfied with the instant notice of payment and the instant disposition, filed a request for review with the National Tax Service on June 5, 2014, but the Commissioner of the National Tax Service dismissed the request for revocation of the instant notice of payment on August 25, 2014, and dismissed the request for revocation of the instant disposition.

[Ground of recognition] Facts without dispute, Gap evidence 20, 21 evidence, Eul evidence 1, 2 and 4 (including each number), the purport of the whole pleadings

2. The actual operator of the Plaintiff’s assertion B or D’s workplace is E, and the Plaintiff is employed by E and worked as a health radar, while lending the Plaintiff’s name at the request of E.

Therefore, the instant notice of payment and the instant disposition imposing value-added tax on the Plaintiff, who is not an actual entrepreneur, are unlawful against the principle of substantial taxation.

3. Attached statements to the relevant Acts and subordinate statutes;

4. Whether the part demanding revocation of principal tax among the instant notice of payment is lawful

A. The Defendant’s main defense of this case’s notice of payment does not constitute a taxation subject to appeal, and thus, the Defendant’s claim for revocation thereof.