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

A. On March 21, 2010, the Plaintiff, a corporation that is engaged in cargo brokerage business, entered into a “contract for the transportation of the president” between C and F, an operator of the “E” (hereinafter the above dump vehicles referred to as “each of the instant vehicles,” and C and F, from 2010 to 2013, received a tax invoice for the transportation of transportation services worth KRW 675,024,581 in total from each of the instant transaction parties (hereinafter the “instant tax invoice”).

Each transaction party of this case reported and paid value-added tax on the above tax invoice, and the defendant deducted the above amount from the input tax amount and reported and paid the value-added tax.

B. As a result of the Plaintiff’s consolidated investigation into the Plaintiff from March 30, 2015 to April 18, 2015, the Defendant: (a) determined that each of the instant transaction parties, even though the Plaintiff performed all of the transportation services-related duties of each of the instant vehicles, was deemed to have been operated as a rolling stock; and (b) deemed that all of the instant tax invoices were false tax invoices, the Defendant did not deduct the input tax amount from the input tax amount; and (c) added the penalty tax for fraudulent tax invoices, the penalty tax for illegal underreporting, and the penalty tax for unfaithful payment, as indicated in the “amount of tax after correction of the amount of tax after correction” as indicated in the “

C. Upon filing an objection on August 11, 2015, the Plaintiff filed a tax appeal on December 31, 2015.

On May 31, 2016, the Tax Tribunal partially accepted the Plaintiff’s claim to the effect that: (a) applying the general under-reported penalty tax, which is not an unfair under-reported penalty tax, to each of the above value-added tax; and (b) the penalty tax paid in bad faith, shall be calculated on the basis of the tax amount calculated by subtracting the value-added tax