A. From July 4, 2006, A Co., Ltd. (hereinafter referred to as “A”) made a decision on January 17, 2012 on commencement of rehabilitation procedures and appointment of a manager for representative director B as Daejeon District Court 201 Ma41, which had been engaged in the business of manufacturing non-metallic metals in Chungcheongnam-gun, Chungcheongnam-gun, Chungcheongnam-gun, Chungcheongnam-do, Daejeon District Court on January 17, 201, and registered as a custodian on January 26, 2012.

B. A purchased waste Dongs, etc. from each of the purchasing partners listed below (hereinafter “each of the instant transaction partners in package”) during the first and second taxable periods of 2010, upon receipt of a tax invoice (hereinafter “each of the instant tax invoices”), and deducted the input tax amount according to the said tax invoices from the output tax amount, and filed a return of value-added tax for the pertinent taxable period with the Defendant by deducting the input tax amount pursuant to the said tax invoices from the output tax amount.

[unit of : 1 D (E) 2,714, 863, 300 2F in 2010 each of the transaction partners of this case; 3,503, 503, 500 G (H) 231,142, 500 7,375, 342, 350 4 6,304,905, 905, 505 J (K) 5, 299, 762, 601, 601, 4766, 476, 479, 707, 608, 6305, 605, 6305, 605, 645, 605, 605, 6305, 605, 605, 605, 607, 607, 6284, 6284, 985, 781,

C. On December 1, 2011, with respect to A, the head of the budget office denied the pertinent input tax deduction for the reason that each of the instant tax invoices received by A from each of the instant transaction parties constitutes a disguised business entity (so-called “data sales”) that issues false tax invoices without real transactions. Each of the instant tax invoices received by A from each of the said transaction parties is a tax invoice different from the facts. As indicated below, KRW 2,660,284,40 for the first term portion of 2010, and KRW 4,504,395,80 for the second term portion of 2010 as indicated below. Meanwhile, the Defendant issued a tax invoice different from the facts to the Plaintiff on December 1, 2012.