A. From July 3, 1981, the Plaintiff runs the wholesale and retail business of electric machinery, tools and tools with the trade name “B”.

B. The Plaintiff issued a purchase tax invoice of KRW 2,458,722,500 (hereinafter “instant tax invoice”) in the taxable period of value-added tax for January 2006 through January 1, 201, by deducting the input tax amount from the output tax amount, and filed a return on and pay the value-added tax by deducting the input tax amount from the output tax amount.

C. The director of the Seoul Regional Tax Office, from May 12, 201 to September 13, 201, issued and issued a processed tax invoice of approximately KRW 9.6 billion to the Plaintiff and 59 companies from January 1, 2006 to December 31, 201, and determined that D and 10 businesses sold without issuing a tax invoice and then notified the Defendant of the taxation data on the Plaintiff.

As a result of the investigation into the part of value-added tax with respect to the Plaintiff, the Defendant: (a) determined that the instant tax invoice was “E” rather than C; and (b) determined that the instant tax invoice was false; (c) determined that the Plaintiff’s tax invoice was “E; and (d) added the amount of value-added tax for one year, 2006 to the Plaintiff on September 4, 2012 on the ground that the Plaintiff under-reported the value-added tax base by improper means; (b) added the amount of value-added tax for 3,374,910; (c) KRW 41,317,510; (d) KRW 35,726,250; (d) value-added tax for 1 year, 207 to 35,726, 250; and (e) KRW 20 to 43,195,570; (d) KRW 41,346,340 for one year, 208 to 2008,485,3948