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

On August 28, 2015, the Plaintiff entered into a sales contract with the following terms: “The Plaintiff shall sell to C the building 501 (hereinafter “instant building”) of the Seo-gu Incheon Building at KRW 2,100,570,000: (a) the down payment amount of KRW 210,057,000 shall be paid on the date of the contract; (b) the remainder of KRW 1,890,513,000 shall be paid as the national bank account in the name of the New Real Estate Trust; and (c) the Plaintiff shall deliver the instant building on September 10, 2015 (hereinafter “instant sales contract”).

B. On September 24, 2015, the Plaintiff completed the registration of ownership transfer with respect to the instant commercial building, and issued an electronic tax invoice (Evidence B; hereinafter “instant previous tax invoice”) with the supply value of KRW 1,505,700,000 on the same day. Pursuant to the content of the instant previous tax invoice, the Plaintiff filed a preliminary return of value-added tax for the second year in 2015.

C. On October 23, 2015, the Plaintiff filed a revised electronic tax invoice (No. 3; hereinafter “instant revised tax invoice”) stating that “C did not pay any balance after the ownership of the instant commercial building was transferred.” On October 23, 2015, the Plaintiff issued the revised electronic tax invoice (No. 3; hereinafter “instant revised tax invoice”) with the content that the total amount of supply stated in the previous tax invoice was deleted, and filed a final tax return for value-added tax of 2015 according to the content of the instant amended tax invoice.

According to the contents of the previous tax invoice of this case, the Defendant issued the instant revised tax invoice with a false tax invoice, and on June 1, 2016, KRW 200,077,410 [Additional Tax KRW 51,196,313 (“Additional Tax 51,196,313”) to the Plaintiff on June 1, 2016.