(1) As of the date of establishment of the tax liability, the second taxpayer is deemed to be an oligopolistic shareholder on the register of shareholders and the second taxpayer.

In light of all circumstances, the plaintiff's assertion that the plaintiff constitutes an oligopolistic shareholder on the register of shareholders as of the date of establishment of tax liability, and only after the date of establishment of tax liability, the plaintiff's assertion that the plaintiff became an oligopolistic shareholder on the register of shareholders is without merit.

Article 39 (Secondary Liability to Pay Taxes by Investor)

2017Nu35136 (Revocation of Disposition of Designation as Person Liable for Secondary Tax Payment)

○○ Co., Ltd.

○ Head of tax office

Seoul High Court Decision 2017Nu35136 Decided October 25, 2017

February 28, 2018

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff, including the part arising from the supplementary participation.

The records of this case and the judgment of the court below and the grounds of appeal were examined. However, the grounds of appeal on the grounds of appeal are not included in the grounds stipulated in each subparagraph of Article 4(1) of the Act on Special Cases Concerning the Procedure for Appeal. Therefore, the appeal is dismissed pursuant to Article 5 of the Act. It is so decided as per Disposition