1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance cited by the court of first instance shall be added to the judgment of the plaintiff's grounds for appeal in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act as stated in paragraph (2) below.

2. (i) The summary of the grounds for appeal by the Plaintiff is that the Plaintiff is merely a shareholder who lent the name of the shareholder of the instant company to C, and that C substantially operates the instant company. Thus, each of the dispositions of the instant case on the ground that the Plaintiff constitutes an oligopolistic shareholder of the instant company is null and void.

If there are objective circumstances that make it possible to misunderstand that any legal relation or fact which is not subject to taxation is subject to taxation, and whether it is subject to taxation can only be identified by accurately investigating the facts, it cannot be said that it is apparent even if the defect is serious, and thus, the taxation summary is not clear even if it is serious.

It can not be deemed that the taxation disposition that misleads the facts into the fact is null and void as a matter of course.

(See Supreme Court Decision 2011Du22723 Decided February 23, 2012, etc.). Examining the overall purport of the facts admitted and the evidence duly admitted in full, the following is the same.

From the time of incorporation of the instant company, the Plaintiff was registered as a shareholder holding 100% of the shares of the instant company in the register of shareholders, and was registered as a representative director in the register of shareholders.

Even if the Plaintiff merely lent the name of the shareholder of the instant company to C and is not the actual shareholder of the instant company, such circumstance can only be found to have been accurately examined, so it is difficult to view that each disposition of the instant case was apparent from appearance. It is difficult to view that the Defendant clearly perceived such circumstance at the time of each disposition of the instant case.

The plaintiff only lends the name of a considerable number of corporations to the law.