Tough-construction is, undoubtedly, one of the most puzzling syntactic problems in the history of transformational grammar. Various approaches have been proposed including Deletion approaches (Akmajian, 1972; Lasnik and Fiengo, 1974) and movement approaches. Among the movement approaches, Chomsky (1977; 1981) argues for movement of null Operator, and Hornstein (2001) argues for a two-step movement equipped with Sideward movement. Most recently, Schueler (2004) and Hartman (2009) each have also argued for a kind of movement approach. With the development of the Minimalist syntax (Chomsky, 1995; Chomsky, 2000; Chomsky, 2001), tough-construction, an age old problem in the description of grammar, turns into another round toward to a more satisfactory answer. By examining the most recent competing analyses of tough-constructions, this paper defends and extends Schueler's (2004) analysis, rather than Hartman's (2009) two step movement approach. Furthermore, this paper proposes that tough-subject originates from the intermediate CP internal Spec-TopicP position rather than from the iterated CP layer (Authier, 1992). This approach has more descriptive power than it was originally argued for in Schueler (2004) and is a step closer toward Minimalism insofar as the conception of government is no longer utilized.