1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. B (hereinafter “B”) was established on January 11, 2006 for the purpose of real estate sale and lease business, etc. and was closed ex officio on June 30, 2010, and the Plaintiff was registered as B’s representative director from December 8, 2006 to January 4, 2008.

B. In the process of processing the value-added tax assessment data in 2007, the head of the same tax office confirmed that he purchased the amount equivalent to KRW 55,279,000 in the supply price in the process of processing the value-added tax assessment data in B, and received the disposition of income as a recognition contribution to the Plaintiff registered as the representative director in the corporate register B at the time of 2007, and notified the Defendant of the taxation data. On April 22, 2013, the Defendant notified the Plaintiff of the rectification of KRW 12,110,720 in the global

(hereinafter “instant disposition”)

C. The Plaintiff, who was dissatisfied with the instant disposition, filed an objection on July 9, 2013, but was dismissed. On December 17, 2013, the Plaintiff filed a request for examination with the National Tax Service, but received a decision of dismissal from the National Tax Service on March 10, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 5-1, 2, Gap evidence 8, Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. (1) The Plaintiff’s assertion 1) The representative who actually operated the instant disposition before the closure of the business is C, and the Plaintiff is only the representative director in the name of B. Nevertheless, the instant disposition based on the premise that the Plaintiff is the actual representative of B is unlawful. 2) The instant disposition was made after the lapse of five years of exclusion period of imposition, and is unlawful.

B. The details of the relevant statutes are as shown in the attached statutes.

C. 1) Determination 1) Whether the Plaintiff is merely a representative director under the name of the Plaintiff is a person who actually exercises the authority of the representative director under the relevant legal doctrine and actually takes part in the management falls under the representative subject to disposition after being recognized as a representative (see Supreme Court Decision 2005Du8030, Jan. 18, 2008), and the representative director of the corporation who is subject to disposition of income by being recognized as a representative.