2. The plaintiff shall bear the litigation costs.

A. From October 21, 2008 to February 6, 2009, the director of the regional tax office of ○○○ has conducted an integrated investigation of corporate tax against the Plaintiff, a corporation engaged in the production, distribution, etc. of women’s clothes, and confirmed that the Plaintiff received a tax invoice of KRW 1,072,627,000 (hereinafter “the processed tax invoice of this case”) from the Plaintiff from 2003 to the 2007, and notified the Defendant of the pertinent amount of the output tax by deducting the pertinent amount of the value-added tax from the output tax return of KRW 8,931,281,337 (hereinafter “the processed tax invoice of this case”) during the taxable period of value-added tax from January 2003 to 2004.

B. Based on the above taxation data, the Defendant: (a) added the processing expenses of this case to KRW 10,003,908,337 (=the processing expenses of this case + KRW 8,931,281,337 + the amount of KRW 1,072,627,000 for the purchase tax invoice of this case; and (b) notified the Plaintiff of KRW 560,221,00 for the corporate tax of March 2, 2003; (c) notified the Plaintiff of the disposition imposing corporate tax of KRW 747,728,40 for the corporate tax of April 1, 2004; and (d) the corporate tax of KRW 663,024,330 for the corporate tax of KRW 663,26,380 for the year 206; and (e) the corporate tax of KRW 836,260 for the corporate tax of KRW 380 for the year 207; and (e.g. 20141.

C. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on July 8, 2009, but the Tax Tribunal dismissed the said appeal on March 19, 2010.

【Ground for Recognition: Facts without dispute; Gap evidence 1-4; Gap evidence 2; Gap evidence 1-4; Gap evidence 1-4; Eul evidence 1-2; Eul evidence 12; the purport of the whole pleadings

2. Whether the dispositions of the instant case are legal.

A. The plaintiff's principal

During the business year from 2004 to 2007, the Plaintiff paid KRW 652,300,000 to the bank account in cash or borrowed from the above employees. ② The Plaintiff’s respective departments paid KRW 912,00,000 as the sales fund for the officers and employees performing the special duties. ③ The Plaintiff’s sales management manager paid KRW 425,20,000 to the Plaintiff’s 30,000 to 50,000 to 50,000 to 200,000 to 30,000 to 1999, the Plaintiff’s 3,598,491,474 to 199 to 3,59,000 to 3,59,000 to 30,000 to 100,000 to 205,000 to 30,000 to 19,000 to 200.

(b) Related statutes;

It is as shown in the attached Form.

C. Determination

(1) In a lawsuit seeking revocation on the grounds of illegality of taxation, the tax authority has the burden of proving the legality of disposition and the existence of the burden of proving the amount of expenses to be included in deductible expenses, which are the basis of determining the amount of corporate tax, as a matter of principle, the tax authority shall bear the burden of proving the amount of expenses to be included in deductible expenses, which are the basis of determining the amount of income. However, in cases where the tax invoice on some of the expenses reported by the taxpayer was proved to be false or falsely prepared without real transactions, or where the taxpayer asserts that the amount of tax invoice was required for the same amount as the taxpayer's own declaration is false, it shall be deemed that the taxpayer needs to prove that it is easy for the taxpayer to produce data, such as books and evidence, regarding the existence and amount of other expenses (see, e.g., Supreme Court Decisions 94Nu5816, Oct. 28, 1994; 2007Du1439, Aug. 20, 209).

(2) As to whether the Plaintiff paid KRW 3,129,50,000 to the business year from 2004 to the business year from 2007, the health care team; the evidence submitted by the Plaintiff is insufficient to believe it as follows; or there is no other evidence to acknowledge it otherwise.

(A) The Plaintiff’s evidence Nos. 1 through 6-1, 11-2, and 11-2 are the list of the employees asserted by the Plaintiff as bad credit holders, the account number of the above employees, the payment account number of the Plaintiff transferred to the above bank account, the payment statement (benefit ledger), the report of performance of withholding taxes, and the confirmation supporting the Plaintiff’s assertion. However, according to each of the above evidence Nos. 5 through 9 (including each number), the Plaintiff reported most of the earned income paid to the employees asserted by the Plaintiff as bad credit holders to the tax authority. Some of the remittance details of the Plaintiff’s assertion were provided from the other party to the Plaintiff’s transaction (FF, KimD, LG, and HH), and some of the Plaintiff’s allegation were deemed to have been recognized as losses. Accordingly, it is difficult to find that the Plaintiff’s assertion that the Plaintiff submitted the above evidence was inconsistent with the Plaintiff’s basic evidence Nos. 1, 2, and 1).

(B) The Plaintiff’s assertion ② Evidence Nos. 7-1 through 7, No. 12-1, and No. 3 are evidence of the Plaintiff’s assertion, i.e., a statement of annual operating expenses and a statement of executive officers and employees supporting the Plaintiff’s assertion. However, it is insufficient to recognize the fact that the cost claimed by the Plaintiff was spent solely on the basis of the above evidence without

(C) The Plaintiff’s assertion-related evidence Nos. 8-1 through 16, No. 12-1, and No. 2 are evidence of the Plaintiff’s assertion, and the store manager’s confirmation supporting the Plaintiff’s assertion. However, it is insufficient to acknowledge that the cost claimed by the Plaintiff was paid solely with the entry of each of the above evidence without the account book or specific disbursement evidence.

(D) It is insufficient to recognize the fact that the Plaintiff’s evidence Nos. 10-1 through 10, which is the evidence of the Plaintiff’s assertion, has been paid for the expenses alleged by the Plaintiff. Meanwhile, each of the Plaintiff’s evidence Nos. 11-1 through 5 (each of the Plaintiff’s evidence Nos. 11-5 (each of the Certificate) is written, and it is difficult to believe it as it is, as it is, no objective evidence, such as the UB, the JJ, the United K, the least K, the LL, and the maximum MM from October 1, 1998 to August 1, 1999, lent KRW 2.8,850,000 to the Plaintiff via the highestCC, the representative director, at an annual interest rate of 10% from around 2003 to 207. This is inconsistent with the Plaintiff’s assertion, and there is no objective evidence, such as financial materials supporting that it was received as above.

(3) Therefore, the plaintiff's assertion is without merit, and the defendant's disposition of this case is legitimate.

3. Conclusion

The plaintiff's claim shall be dismissed without reason.