A. The Plaintiff is a company established on April 8, 2008 and engaged in scrap metal processing and wholesale business with its head office located in Daejeon building and the second floor.

B. From the first to the first half of the year 2013, the Plaintiff received purchase tax invoices of KRW 82,963,003,084 in total from 461 buyers in each of the following taxable periods: (a) deducted the input tax amount from the output tax amount in 2,061; and (b) filed a return on the first half and second half of the year 2013, the first half of the year 2014 and the corporate tax for 2013 and 2014; (c) among them, the details of the tax invoices issued from C, D (hereinafter “D”), and E are as follows.

349,158,300 E 382,01,957,60 won in the second period C 313,113,850 won in 2013, 2013, C 109,351,350 won in aggregate of the supply value of purchase of tax invoices by the purchaser in the taxable period, 13,351,256,650 won in the first period E 14, 2014

C. On July 1, 2015, from around August 1, 2015 to August 31, 2015, the commissioner of the Daejeon Regional Tax Office determined that the above tax invoice received from C, D, and E constituted a false tax invoice and notified the Defendant thereof.

Accordingly, the Defendant considers that the Plaintiff’s tax invoice received from C, D, and E (the total tax invoice received from D and E, hereinafter “instant tax invoice”) as a false tax invoice and increases the tax base of value-added tax by denying the deduction of the relevant input tax amount, and applying the additional tax on non-collection of the certificate of payment of corporate tax (additional tax) for the first period portion of value-added tax for the year 2013 to the Plaintiff on November 5, 2015, respectively. < Amended by Act No. 14, 14,177,87,870, value-added tax for the second period of the year 2013; Act No. 398,22,280, value-added tax for the second period of the year 2013; Act No. 50,595,000, corporate tax for the year 200,000, corporate tax for the year 2013; Act No. 727,640, Jul. 7, 2014>