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 reasons why this part of the disposition is stated are as follows. Article 39 of the Framework Act on National Taxes provides that where the property of a corporation is insufficient to cover “national taxes, additional dues and expenses for disposition on default,” which the person who falls under each of the following subparagraphs as of the date on which the liability to pay national taxes is established shall be subject to secondary tax liability for the shortage. According to Article 12 of the National Tax Collection Act, when the head of a tax office intends to collect the delinquent amount of a taxpayer from the secondary taxpayer, he/she shall notify the secondary taxpayer of the notice of payment stating the items of taxation, the calculation basis of the delinquent amount, the payment period, the place of payment, the amount to be collected from the secondary taxpayer, and other necessary matters, separate from the primary liability to pay taxes, and the secondary liability to pay taxes is established and confirmed abstractly, and the secondary liability to pay taxes is also determined by the notice of payment stating that additional dues are collected from the primary taxpayer (see, e.g., Supreme Court Decision 2012Du8184, Feb. 28, 1982).