A. The Plaintiff is a company running a business on August 14, 1990 and running an imported alcoholic beverage wholesale business in Daegu Suwon-gu. The Plaintiff’s actual manager, as at the time of the following tax investigation, changed the Plaintiff’s trade name into G Co., Ltd (current, “B Q”) with smaller size than that of the Plaintiff.

hereinafter referred to as "G"

2) On April 3, 2018, the Defendant succeeded to the authority of the head of the Dong Daegu District Tax Office to take measures to state the purport of the claim and received a decision of correction from the Defendant on June 12, 2018.

B. (1) Around November 2013, the head of the Nam Daegu District Tax Office confirmed that the said main office purchased two shares from the Plaintiff with non-data and deposited the price into the bank account in the name of D, an employee of the Plaintiff. (2) Accordingly, the head of the Daegu District Tax Office selected the Plaintiff as a person subject to investigation from March 13, 201 to May 22, 2014, and conducted a liquor distribution tracking investigation against the Plaintiff for the two taxable periods from March 13, 2014 to May 22, 2014.

3) The director of Daegu Regional Tax Office may issue sales tax invoices to the Plaintiff’s customer and 19 bank accounts among 27 bank accounts in the names of 11 shareholders E and employees D, etc. of the Plaintiff (hereinafter collectively referred to as “each of the instant accounts”).

(C) After examining the details of financial transactions with respect to the Plaintiff, the Plaintiff issued to 104 business parties, which were the sum of supply amounts of 2,841,046,973 won in total, at least 10% of gross sales, and issued an excessive amount of sales tax invoices of the amount equivalent to that amount to the Plaintiff, and notified the Defendant of the taxation data. (3) The Defendant was the Plaintiff on July 1, 2014, as amended by Act No. 10409, Dec. 27, 2010; and (4) as Act No. 11873, Jun. 7, 2013.