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

A. From May 23, 2005, the Plaintiff received a tax invoice of KRW 1,003,327,272 (hereinafter “instant tax invoice”) from Nonparty D Co., Ltd. (hereinafter “D”) in 2009, and received the tax invoice of KRW 1,454,54,54,209, the supply price of KRW 493,927,273,209, and the supply price of KRW 1,94,945,45, and KRW 1,003,327,272 from Nonparty Co., Ltd. (hereinafter “D”).

B. On August 1, 2011, the Commissioner of the Central Regional Tax Office notified the Defendant of the fact that “1,003,327,272 won, which the Plaintiff purchased from D as data, was “processed Purchase” as taxation data. The Defendant, on August 1, 201, issued a revised notice of KRW 16,763,250, value-added tax for the first term portion of value-added tax for the year, 2009, KRW 75,06,00,00, and KRW 86,763,250, and value-added tax for the second term of February 2009, KRW 16,159,710 (hereinafter “instant disposition”).

C. The Plaintiff appealed and filed an appeal with the Tax Tribunal on July 19, 2012 on November 8, 201, but all the appeals were dismissed.

[Reasons for Recognition] Facts without dispute, Gap evidence 1-1-3, Gap evidence 2, Gap evidence 6-1-12, Gap evidence 8-1, 2, Eul evidence 1-1 through 3, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The Plaintiff purchased oil from D and received the instant tax invoice, and thus, the instant tax invoice cannot be deemed to constitute a false tax invoice. 2) The Plaintiff did not know that D was an actual supplier of oil, such as confirming D’s petroleum sales business registration certificate and business registration, and remitting oil price to D bank accounts under the name of D, and was not negligent in not knowing that D was the actual supplier of oil.

(b) Entry in the attached statutes of the relevant statutes;

C. The sales tax invoice of this case is one of the tax invoices.