1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On May 1, 2003, the Plaintiff leased a 188.43 square meters of the 1st floor of the building in Gangnam-gu Seoul, Seoul (hereinafter “instant commercial building”) and operated a restaurant after registering the business of “general restaurant business”. On June 13, 2008, the Plaintiff entered into a contract with the New Round (hereinafter “New Round”) on the transfer of the right to lease, facilities, etc. of the instant commercial building at KRW 300 million between the New Round (hereinafter “New Round”), and handed over the instant commercial building on July 1, 2008.

(hereinafter “instant transaction”). (b)

On June 30, 2008, the Plaintiff filed a report on the closure of business, and on August 1, 2008, the New World Tagazur made a business registration with the trade name of “Cheongdam 8,” the location of the instant commercial building,” and the type of the business as “hump and miscellaneous retail.”

C. The Plaintiff did not file a value-added tax return on the transfer of the instant transaction with the New World Twits Day, regarding the transfer of the business subject to non-taxation of value-added tax. However, on July 8, 2013, the Defendant reported the transfer of the instant transaction, not the comprehensive transfer of the business, and determined and notified the Plaintiff of KRW 50,255,450 (including additional tax 22,982,725) in 208.

(hereinafter “instant taxation disposition”). D.

The Plaintiff filed an objection on September 6, 2013, but was dismissed. On December 24, 2013, the Plaintiff filed a request for examination with the Commissioner of the National Tax Service, but the Commissioner of the National Tax Service dismissed the said request on March 8, 2014.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1 and 2, Eul evidence Nos. 1, 2, 4, 5, 6, and 9, and the purport of the whole pleadings

2. Whether the instant taxation disposition is legitimate

A. The Plaintiff asserted that the Plaintiff comprehensively transferred the entire business, including the right of lease, goodwill, and all facilities of the instant commercial building, on the New Together Day.

The type of business has been changed after the New Round and then the type of business has been changed in the commercial building in this case, which is not a restaurant.