[edit] Supreme Court Decision 98Da47184 delivered on February 25, 2000 [Unjust Enrichment]
【Main Issues】
[1]Whether the television broadcast receiving fee collected by the Korea Broadcasting System is a compensation for the broadcasting service it provides (negative); The object for the exemption from the taxation of value-added tax (i.e., general broadcasting service provided by revenue from receiving fees) and the object for the taxation of value-added tax (i.e., commercial broadcasting provided by revenue from advertisement fees) among the broadcasted programs of the Korea Broadcasting System
[2]Whether the Korea Broadcasting System is permitted to calculate the input tax amount for the commercial broadcasting to be deducted from its value-added tax amount in proportion to the ratio of the advertising revenue to the aggregate revenue consisting of the advertising fees as well as the receiving fees, by applying directly or by analogy the main sentence of Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act (negative)
[3]Whether the Korea Broadcasting System is obligated to pay corporate tax on its revenues from advertising fees, radio wave usage fees, and the symphony orchestra (affirmative)
【Summary of Decision】
[1] The receiving fees are collected from the persons who possess a television receiver for the purpose of receiving television broadcasts (Article 35 of the Korea Broadcasting System Act amended by Act, Law No. 4264 of August 1, 1990), the amount of the receiving fee is fixed by the deliberation and resolution of the board of directors of the Korea Broadcasting System and shall be imposed and collected by the Korea Broadcasting System upon obtaining the approval of the Government Information Agecy (currently the Ministry of Culture and Government Information) (Article 36 of the same Act), and the punitive surcharge or the additional charge shall be imposed by the Korea Broadcasting System upon failure to register as a television receiver or to timely pay the receiving fee and any person who delays in payment of such amount may be subject to the collection in accordance with the disposition on the national tax in arrears (Article 37 of the same Act). In light of the above regulations, the receiving fee shall be deemed as a special charge imposed on the specific group possessing television receivers to meet the expenditures for a specific public service of a public-managed broadcasting service and, thus, cannot be considered as a compensation for the service provided by the Korea Broadcasting System. Consequently, the broadcasting of the Korea Broadcasting System funded wholly by revenues from the receiving fee shall be deemed as a supply of service without compensation in relation to the general viewers which shall be the object for the exemption from the taxation of value-added tax as provided by Paragraph 3 of Article 7 of the former Value-Added Tax Act (amended by Act, Law No. 5032 of December 29, 1995) unless there exist special circumstances to recognize a compensatory relationship such as the relevancy to the commercial broadcasting, and the broadcasting business conducting the same as a business cannot also be considered as taxable business for the taxation of value-added tax. On the other hand, Item 7, Paragraph 1 of Article 12 of the same Act excludes the advertising from the object for non-taxation of value-added tax while it provides the broadcasting as the object for non-taxation of value-added tax. Therefore, commercial broadcasting funded by the revenues from the advertising fee shall be considered as the object for taxation of value-added tax, and the broadcasting business conducting the same as a business shall also be considered as the taxable business for the taxation of value-added tax.
[2] Since the broadcasting business actually conducted by the Korea Broadcasting System is neither a taxable business nor a tax-free business for value-added tax taxation purposes, the Korea Broadcasting System is deemed to conduct only such broadcasting business that is a taxable business for value-added tax taxation purposes under the Value-Added Tax Act. Therefore, when calculating the input tax amount to be deducted from the amount of value-added taxes payable by the Korea Broadcasting System, the first sentence of Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act (amended by Presidential Decree No. 14863 of December 30, 1995) which is applicable to the case of the concurrent operation of a taxable business and a tax-free business cannot be applicable to the calculation of the input tax amount commonly used for the taxable business and the tax-free business and unable to distinguish the attributions thereof. In addition, the formula provided in the first sentence of Paragraph 1 of Article 61 of the same Act cannot apply by analogy to such a calculation because the supply of the broadcasting service by the Korea Broadcasting System funded by revenues from the receiving fee shall be deemed as a supply of service without compensation and the value of such supply cannot be ascertained. Therefore, under Article 17 of the former Value-Added Tax Act (amended by Law No. 5032 of December 29, 1995), the tax amount on the supply of goods and services either used or to be used for the advertising business that is a taxable business (Paragraph 1) can be deducted as the input tax amount to the extent such amount does not fall under the exceptions provided in Paragraph 2 thereof.
[3] Since the proviso to Paragraph 1 of Article 1 of the former Corporate Tax Act (amended by Act, Law No. 4804 of December 22, 1994) provided that, for the non-profit domestic corporation, the corporate taxes were to be imposed only on the income obtained through business or revenue listed in each of the following items notwithstanding the business purpose specified in the articles of incorporation or internal rules of such corporation and subsequently provided the types of profit-making business or revenue subject to the corporate tax in items 1 through 7 thereof, any income obtained through such listed profit-making businesses or revenues shall be subject to the corporate tax to the extent that such business or revenue falls under the items 1 through 7 of the above-stated proviso regardless of whether it is intended to fulfill the stated business purpose of a non-profit corporation. Although the broadcasting business conducted by the Korea Broadcasting System is a supply of service without compensation and cannot therefore be considered as a profit-making business in itself, it is evident that the advertising business conducted by the Korea Broadcasting System as a profit-making business falls under the 'advertising or newspaper delivery management business' among the 'enterprise service business' as provided in Item 4, Subparagraph (Ra) of Article 36 of the former Enforcement Decree to the Income Tax Act (amended by Presidential Decree No. 14467 of December 31, 1994), considering the provisions of Item 1, Paragraph 1 of Article 1 of the above-mentioned former Corporate Tax Act which provided the profit-making business of non-profit corporations subject to the corporate tax as the businesses prescribed by the Presidential Decree among the livestock, forestry and fishery, mining, manufacturing, electricity·natural gas·water supply, construction, wholesale, retail·food·lodging, transportation·storage·telecommunications, finance·insurance, real estate·corporate service and social service· personal service businesses and Paragraph 1 of Article 2 of the former Enforcement Decree to the Corporate Tax Act (amended by Presidential Decree No. 14468 of December 31, 1994) which provided the scope of the business under Item 1, Paragraph 1 of Article 1 of the same Act to be the businesses subject to the provisions of Articles 29 through 37 of the Enforcement Decree to the Income Tax Act and the real estate leasing business. Therefore, the Korea Broadcasting System is obligated to pay corporate tax on its revenues from advertising fees, radio wave usage fees and the symphony orchestra, etc.
【Reference Provisions】 [1] Article 35 (See Article 64 of the present Broadcasting Act), Article 36 (See Article 65 of the present Broadcasting Act) and Article 37 (See Article 66 of the present Broadcasting Act) of the former Korea Broadcasting System Act (repealed by Article 2 of Addendum to the Broadcasting Act, Law No. 6139 of January 12, 2000), Paragraph 3 of Article 7 and Item 7, Paragraph 1 of Article 12 of the former Value-Added Tax Act (amended by Act, Law No. 5032 of December 29, 1995) / [2] Paragraphs 1 and 2 of Article 17 of the former Value-Added Tax Act (amended by Act, Law No. 5032 of December 29, 1995), Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act (amended by Presidential Decree No. 14863 of December 30, 1995) / [3] Paragraph 1 of Article 1 and Paragraph 1 of Article 2 of the former Corporate Tax Act (amended by Act, Law No. 4804 of December 22, 1994), Item 4 Subparagraph (Ra) of Article 36 of the former Enforcement Decree to the Corporate Tax Act (amended by Presidential Decree No. 14467 of December 31, 1994)
Article 35 of the former Korea Broadcasting System Act (repealed by Article 2 of Addendum to Broadcasting Act, Law No. 6139 of January 12, 2000) (Registration of Television Receivers and Payment of Receiving Fees) Any person who possesses a television receiver (hereinafter referred to as "TV set") in order to receive television broadcasts shall register the TV set with the System, and pay a television broadcast receiving fee (hereinafter referred to as the "receiving fee(s)") under the conditions as prescribed by the Presidential Decree; provided, that with regard to the TV sets as prescribed by the Presidential Decree, their registration may be exempted, or all or part of the receiving fees may be exempted or reduced.
Article 36 of the former Korea Broadcasting System Act (repealed by Article 2 of Addendum to Broadcasting Act, Law No. 6139 of January 12, 2000) (Determination of Receiving Fees) (1) The amount of receiving fees shall be fixed by the deliberation and resolution of the board of directors, and shall be imposed and collected by the System upon obtaining the approval of the Ministry of Culture and Government Information.
(2) The Ministry of Culture and Government Information shall consult with the Ministry of Finance and Economy prior to the approval as referred to in Paragraph 1 above.
Article 37 of the former Korea Broadcasting System Act (repealed by Article 2 of Addendum to Broadcasting Act, Law No. 6139 of January 12, 2000) (Collection of Receiving Fees, etc.) (1) The System shall, in collecting the receiving fees under the provisions of the Paragraph 1 of Article 36, and in case where a person liable to pay the receiving fees fails to pay them within the relevant payment period, collect an additional charge in the amount equivalent to the rate as prescribed by the Presidential Decree within the limit of 5/100 of the relevant receiving fees.
(2) The System shall impose and collect from any possessor of a TV set which is not registered under Article 35 a punitive surcharge equivalent to the receiving fees for one year.
(3) The System may, in collecting the receiving fees under Paragraph 1 of Article 36, and the additional charge or the punitive surcharge under Paragraphs 1 and 2, and in case where there exists any delinquency of payment, collect them in accordance with the examples of disposition on the national tax in arrears by obtaining approval of the Ministry of Culture and Government Information
Article 7 of the former Value-Added Tax(amended by Act, Law No. 5032 of December 29, 1995) (Supply of Services) (1), (2) <omitted>
(3) The supply of services to others without compensation or the supply of labor under an employment relationship shall not be considered as the supply of services.
(4) <omitted>
Article 12 of the former Value-Added Tax(amended by Act, Law No. 5032 of December 29, 1995) (Tax Exemption) (1) The supply of such goods or services as provided in any of the following items shall be exempted from value-added taxes:
1.~6. <omitted>
7. Books, newspapers, magazines, official gazettes, telecommunications and broadcasting as prescribed by the Presidential Decree; provided, that advertisements shall be excluded
8.~18. <omitted>
(2)~(5) <omitted>
Article 17 of the former Value-Added Tax(amended by Act, Law No. 5032 of December 29, 1995) (Payable Tax Amount). (1) The amount of value-added taxes payable by an entrepreneur hereinafter referred to as a "payable tax amount") shall be the amount computed by deducting the tax amount under the following Items (hereinafter referred to as an "input tax amount") from the tax amount on the goods and services supplied by the entrepreneur (hereinafter referred to as "output tax amount"); provided, that where an input tax amount exceeds the output tax amount, it shall be a refundable tax amount (hereinafter referred to as a "refundable tax amount"):
1. The tax amount on the supply of goods and services either used or to be used for the entrepreneur's own business
2. The tax amount on the import of goods either used or to be used for the entrepreneur's own business.
(2) The input tax amount under the following Items shall not be deducted from the output tax amount:
1. Input tax amount, in case where the list of the total tax invoices by customer is not submitted under Paragraphs 1 and 2 of Article 20, or input tax amount on the portion not entered or entered differently from the fact, in case where the whole or a part of the registration numbers or supply prices by transaction parties are not entered or entered differently from the fact; provided, that the input tax amount in such cases as prescribed by the Presidential Decree shall be excluded
1-2. Input tax amount, in case where the tax invoice as provided in Paragraphs 1 and 3 of Article 16 is not delivered, or the whole or part of the matters to be entered under Items 1 through 4 of Paragraph 1 of Article 16 (hereinafter referred to as a "requisite entry item") is not entered or entered differently from the fact on the delivered tax invoice; provided, that the input tax amount in such cases as prescribed by the Presidential Decree shall be excluded
2. Input tax amount on disbursements which are not directly related to the business
3. Input tax amount on the purchase and maintenance of small non-business automobiles
3-2. Input tax amount related to the disbursement of such expenses as are prescribed by the Presidential Decree, i.e. entertainment expenses and similar expenditures
4. Input tax amount related to the business supplying goods or services which are exempted from the value-added taxes(including input tax amount related to investments), and input tax amount related to lands as prescribed by the Presidential Decree
5. Input tax amount prior to filing a registration under the provisions of Paragraph 1 of Article 5
(3)~(6) <omitted>
Article 61 of the former Enforcement Decree to the Value-Added Tax Act(amended by Presidential Decree No. 14863 of December 30, 1995) (Proportionate Calculation of the Input Tax Amount) (1) When an entrepreneur concurrently operates a taxable business and a tax-free business, the input tax amount related to the tax-free business shall be calculated based on the actual attribution; provided, that the input tax amount commonly used for the taxable business and the tax-free business and unable to distinguish the attributions thereof (hereinafter referred to as a "common input tax amount") shall be calculated by the following formula; provided, further, that the provisional tax return shall be made based on the proportionate ratio of the tax-exempt value of supply to the aggregate value of supply, which shall be adjusted at the time of filing the final tax return.
Input Tax Amount related to the Tax-Free Business
Common input tax amount ×
Tax-Exempt Value of Supply
Aggregate Value of Supply
Article 1 of the former Corporate Tax Act (amended by Act, Law No. 4804 of December 22, 1994) (Tax Liability). (1) A corporation with its headquarter or main office in the Republic of Korea (hereinafter referred to as "domestic corporation") shall be liable to pay corporate tax under this Act; provided, that, for a domestic corporation established under Article 32 of the Civil Code or Article 10 of the Private School Act or other special Act with the purpose of establishment which is similar to the corporation under Article 32 of the Civil Code (hereinafter referred to as "non-profit domestic corporation"), corporate taxes shall be imposed only on income obtained through business or revenue under each of the following Items notwithstanding the business purpose specified in the articles of incorporation or internal rules of such a corporation:
1. Businesses prescribed by the Presidential Decree among livestock, forestry and fishery, mining, manufacturing, electricity·natural gas·water supply, construction, wholesale, retail·food·lodging, transportation·storage·telecommunications, finance·insurance, real estate·corporate service and social service·personal service businesses
2. Medical business
3. Interest, discounts, and profits under the provisions of each Item of Paragraph 1 of Article 17 of the Income Tax Act
4. Dividends or funds distributed under the provisions of each Item of Paragraph 1 of Article 18 of the Income Tax Act
5. Revenue arising from the transfer of stocks, warrants or contributed shares
6. Revenue arising from the disposal of fixed capital(not including fixed capital used directly for appropriate business purposes as prescribed by the Presidential Decree)
7. Revenue arising from continuing action other than that under Items 1 through 6 as prescribed by the Presidential Decree
(2)~(5) <omitted>
Article 2 of the former Corporate Tax Act (amended by Act, Law No. 4804 of December 22, 1994) (Scope of Taxable Income). (1) Corporate tax shall be imposed on income under each of the following Items:
1. Income of each business year
2. Liquidation income
(2) <omitted>
Article 36 of the former Enforcement Decree to the Income Tax Act (amended by Presidential Decree No. 14467 of December 31, 1994) (Scope of Finance, Insurance and Real Estate Businesses and Enterprise Service Business) The income under item 8, Paragraph 1 of Article 20 of the Act shall mean the income arising from any of the following Items:
1.~3. <omitted>
4. Enterprise service business(excluding the academic research service and the freelancing business under the provisions of Article 38)
(i)~(iii) <omitted>
(iv) Advertising industry or newspaper delivery management business
(v)~(xii) <omitted>
【Plaintiff, Appellant】 Korea Broadcasting System (Law Office Somyung, Attorney Kyung Soo-keun, Counsel for plaintiff-appellant)
【Defendant, Appellee】 Republic of Korea and 1 other (Attorney Ko Seung-duk, Counsel for defendant-appellee)
【Court of First Instance】 Seoul District Court Judgment 94Gahap97445 delivered on August 14, 1997
【Court of Second Instance】 Seoul Hight Court Judgment 97Na43552 delivered on August 21, 1998
【Disposition】 The appeal shall be dismissed. All costs of appeal shall be assessed against the plaintiff-appellant.
【Reasoning】 The grounds for appeal are examined as follows. Supplementary grounds submitted after the legal due date are examined only to the extent that they concern grounds for appeal submitted within the due date.
1. With respect to the value-added tax
In light of the regulations that the television broadcast receiving fees are collected from the persons who possess a television receiver for the purpose of receiving television broadcasts {Article 35 of the Korea Broadcasting System Act (amended by Act, Law No. 4264 of August 1, 1990)}; the amount of the receiving fees are fixed by the deliberation and resolution of the board of directors of the Korea Broadcasting System and shall be imposed and collected by the Korea Broadcasting System upon obtaining the approval of the Government Information Agency (currently the Ministry of Culture and Government Information) (Article 36 of the same Act); the punitive surcharge or the additional charge shall be imposed by the Korea Broadcasting System upon any person who fails to register a television receiver or to timely pay the receiving fee; and any person who delays in payment of such amount may be subject to the collection in accordance with the examples of disposition on the national tax in arrears (Article 37 of the same Act), the receiving fee shall be deemed as a special charge imposed on the specific group possessing television receivers to meet the expenditures for a specific public service of the public-managed broadcasting service and cannot therefore be considered as a compensation for the service provided by the Korea Broadcasting System. Consequently, the broadcasting of the Korea Broadcasting System funded wholly by revenues from the receiving fees shall be deemed as a supply of service without compensation in relation to the general viewers that is the object for non-taxation of value-added tax as provided by Paragraph 3 of Article 7 of the former Value-Added Tax Act (amended by Act, Law No. 5032 of December 29, 1995) unless there exist special circumstances to recognize a compensatory relationship such as the relevancy to the commercial broadcasting and, therefore, the broadcasting business conducting the same as a business cannot be considered as a taxable business for the purpose of the taxation of the value-added tax. On the other hand, Item 7, Paragraph 1 of Article 12 of the same Act excludes the advertising from the object for non-taxation of value-added tax while it provides the broadcasting as the object for non-taxation of value-added tax. Therefore, commercial broadcasting funded by the revenues from the advertising fee shall be considered as the object for taxation of value-added tax and, thus, the broadcasting business conducting the same as a business shall be considered as a taxable business for the purpose of the taxation of the value-added tax.
With the foregoing duly acknowledged, since the broadcasting business actually conducted by the Korea Broadcasting System is neither a taxable business nor a tax-free business for the purpose of the taxation of value-added tax, the Korea Broadcasting System is deemed to conduct only the broadcasting business that is a taxable business for the purpose of the taxation of value-added tax under the Value-Added Tax Act. Therefore, when calculating the input tax amount to be deducted from the amount of value-added taxes payable by the Korea Broadcasting System, the main sentence of Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act (amended by Presidential Decree No. 14863 of December 30, 1995) which is applicable to the case of concurrently operating a taxable business and a tax-free business cannot apply to the calculation of the input tax amount commonly used for the taxable business and the tax-free business and unable to distinguish the attributions thereof. In addition, the formula provided in the main sentence of Paragraph 1 of Article 61 of the same Act cannot apply to such a calculation because the supply of the broadcasting service by the Korea Broadcasting System funded by revenues from the receiving fees shall be deemed as a supply of service without compensation and the value of supply cannot be ascertained. Therefore, under Article 17 of the former Value-Added Tax Act (amended by Act 5032 of December 29, 1995), the tax amount on the supply of goods and services either used or to be used for the advertising business that is a taxable business (Paragraph 1) can be deducted as the input tax amount to the extent such amount does not fall under the exceptions as provided in Paragraph 2 thereof.
Therefore, the plaintiff's filing of the value-added tax amount by deducting the input tax amount for the commercial broadcasting by calculating the proportionate ratio of the revenue from the advertising fees to the aggregate revenue (i.e., the aggregate sum of the revenue from advertising fees and receiving fees, etc.), without dividing and confirming the portion associated with the advertising business, is illegal in light of the above legal principles, and the judgment of the court below that upheld such filing as an application by analogy of the Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act shall not be justified.
However, in the type of taxes paid by reporting and filing by the taxpayer such as the value-added tax, the tax obligation is formatively confirmed by the act of the taxpayer reporting and filing its own tax base and the tax amount, and the payment of the tax amount is deemed to be a performance of the tax obligation formatively confirmed by such reporting. The national or municipal governments retain the tax amount paid based on the tax claim confirmed by the above procedure. Therefore, unless the tax filing of the taxpayer is null and void due to a material and clear defect, it cannot be forthwith deemed as unjust enrichment. In considering whether a tax filing is null and void due to a material and clear defect, a reasonable judgment must be made upon teleological review of the purpose, significance and function of the regulation under which the tax filing has been made and the available remedies for the defective tax filing as well as a case-by-case consideration of the circumstances leading to the tax filing. (See Supreme Court Decision 94Da60363 delivered on December 5, 1995, Supreme Court Decision 97Da8427delivered on November 11, 1997, etc.)
In light of the facts established on the records in this case, including the fact that the plaintiff did not distinguish the profit-making business and other businesses in its accounting; the fact that it is an open question of the construction of law whether the first sentence of Paragraph 1 of Article 61 of the former Enforcement Decree to the Value-Added Tax Act can be applied by analogy to the case where the taxable and non-taxable businesses are concurrently conducted; and the fact that the plaintiff paid the value-added tax examined in this case without any reservation until it was indicated during the National Assembly's annual inspection for the year 1993 that the payment of the corporate tax was improper which led to the filing of this suit, it is difficult to regard the above defect as overtly clear. Therefore, the above mistake in the judgment of the court below did not affect the outcome of the judgment as long as the tax filing at issue in this case was not null and void per se, and the ground for appeal asserted by the plaintiff-appellant pointing out this issue cannot be accepted.
2. With respect to the corporate tax, defense tax and residence tax as surcharge to corporate tax
The court below determined that, since the proviso to Paragraph 1 of Article 1 of the former Corporate Tax Act (amended by Act, Law No. 4804 of December 22, 1994) provided that the corporate taxes for the non-profit domestic corporation were to be imposed only on income obtained through business or revenue under each of the following Items notwithstanding the business purpose specified in the articles of incorporation or internal rules of such corporation and subsequently provided the type of profit-making business or revenue subject to the corporate tax in Items 1 through 7 thereof, any income obtained through certain profit-making business or revenue was to be subject to the corporate tax to the extent that such business or revenue fell under the Items 1 through 7 of the above-mentioned proviso regardless of whether it was intended to fulfill the stated business purpose of a non-profit corporation. The court below further determined that, although the broadcasting business conducted by the Korea Broadcasting System was a supply of service without compensation and could not therefore be considered as a profit-making business in itself, it was evident that the advertising business conducted by the Korea Broadcasting System as a profit-making business fell under the 'advertising or newspaper delivery management business' among the 'enterprise service business' (as provided as the 'service business' before amended by Presidential Decree No. 13194 of December 31, 1994) as provided in Item 4, Subparagraph (Ra) of Article 36 of the former Enforcement Decree to the Income Tax Act (amended by Presidential Decree No. 14467 of December 31, 1994) considering the provisions of Item 1, Paragraph 1 of Article 1 of the above-stated former Corporate Tax Act which provided the profit-making business of non-profit corporations subject to the corporate tax as the businesses prescribed by the Presidential Decree among the livestock, forestry and fishery, mining, manufacturing, electricity·natural gas·water supply, construction, wholesale, retail·food·lodging, transportation·storage·telecommunications, finance·insurance, real estate·corporate service and social service·personal service businesses and Paragraph 1 of Article 2 of the former Enforcement Decree to the Corporate Tax Act (amended by Presidential Decree No. 14468 of December 31, 1994) which provided the scope of the business under Item 1, Paragraph 1 of Article 1 of the same Act as the businesses within the scope of the provisions of Articles 29 through 37 of the Enforcement Decree to the Income Tax Act and the real estate leasing business. On the foregoing grounds, the court below concluded that the Korea Broadcasting System was obligated to pay corporate tax on its revenues from advertising fees, radio wave usage fees and the symphony orchestra, etc.
The above judgment of the court below shall be justified, and the ground for appeal asserted by the plaintiff-appellant to the effect that the plaintiff did not conduct the profit-making business under any Items of the proviso to Article 1 of the former Corporate Tax Act based on the premise that it conducted a single broadcasting business under the stated business purpose and not an advertising business shall not be justified.
3. Accordingly, all appeals shall be dismissed and all costs of the appeal shall be assessed against the plaintiff-appellant. This decision is delivered with the assent of all Justices who reviewed the appeal.
Justices Lee Im-soo (Presiding Justice)
Lee Don-hui
Song Jin-hun
Yoon Jae-sik (Justice in charge)
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