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

Purport of claim and appeal

The Defendant’s disposition of imposition of global income tax of KRW 18,704,90 for the year 2003 against the Plaintiff on April 4, 2008 and global income tax of KRW 30,048,710 for the year 2004 shall be revoked.

가. 원고는1991. 9. 20.부터2006. 9. 30.까지 '▢▢상사'라는상호로▣▣시▣월동

In 466-1, the Do Governor engaged in the Domination (non-charge, tax refining, food, miscellaneous, etc.).

B. The Plaintiff purchased goods from 4,7280,000 won, 6,060,000 won from her business place of ○○○○○, Inc. (hereinafter “○○○”) and reported the global income tax to the Defendant by including the purchase amount in necessary expenses.

C. According to the result of the investigation of the distribution process of the ○○○ Office’s ○○ Office, the head of the tax office notified the Defendant of the taxation data that the amount of KRW 3,206,00 (the amount of KRW 4,7280,000,000,000 (the amount of KRW 4,7280,000,000,000,000,000,000,000 won (the amount of KRW 6,00,000,000,000,000,000,000,00

D. On April 4, 2008, the Defendant made a disposition to correct the global income tax amount of KRW 18,704,90 for the year 2003, and KRW 30,04 for the year 2004, and KRW 710 for the Plaintiff on April 4, 2008 (hereinafter “instant disposition”).

E. The Plaintiff filed an appeal with the Tax Tribunal on October 22, 2008, but the Tax Tribunal dismissed the Plaintiff’s appeal on February 9, 2009.

[Ground of recognition] Facts without dispute, Gap evidence 1-1, 2, Gap evidence 2, 4-1, Eul evidence 4-1, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

(1) The Plaintiff actually purchased goods from the ○○ Business Office and settled them in cash. The instant tax invoice was issued to the Plaintiff during the said transaction process. However, Park○, an employee in charge of the business of the ○ Business Office, did not properly enter the said details of transactions into the ○○○ Computer Ledger. This is because Park○ did not enter the said details of transactions into the ○○ Business Office’s computer ledger. This is because, for the Plaintiff, Park○, an employee in charge of the business of the ○ Business Office, Park○ did not have properly entered the said details of transactions into the ○○ Business Office’s electronic data. This is because, for the Plaintiff, the ○○○ Office did not grant the ○ Business Office’s serial number to enter

(2) As above, the instant disposition, which did not recognize the purchase amount as necessary expenses, was unlawful despite the existence of the instant tax invoice corresponding thereto between the Plaintiff and the ○○○ Business Office.

(b) Fact of recognition;

(1) The Plaintiff filed a value-added tax return with the head of ○○ Tax Office along with a tax invoice that purchased and received goods from the ○○ Business Office (hereinafter “instant tax invoice”).

(2) On May 2007, the head of the ○○ Tax Office determined the purchase tax invoice reported by the Plaintiff as the result of the distribution process tracking of the ○○ Business Office’s distribution, and notified the Plaintiff of the rectification of the value-added tax equivalent to the amount reported as the input tax amount, and notified the Defendant of the above taxation data.

(3) The Plaintiff paid the value-added tax as revised and notified as above.

(4) Between 271 minutes and 2004, 2003 and 107, 347,000 won were issued between 271 minutes and 2004. Of them, 92, 120,000 won were issued through disguised processing.

(5) The details of the instant tax invoice’s 15,227,00 won out of the 271 minute 2003 271 transaction are consistent with the head of the computerized ledger of the ○○ Business Office, but the remaining details of the tax invoice are inconsistent.

[Ground of recognition] Facts without dispute, Eul evidence 4-5 to 8, Eul evidence 6-2, Eul evidence 7-2, Eul evidence 8-2, Eul evidence 13-3, the purport of the whole pleadings

C. Determination

(1) The key issue of the instant case is whether the purchase amount was the actual transaction between the Plaintiff and the ○○○ Business Office. The following facts are as follows: ① (i) around 90% of the tax invoice issued by the Plaintiff at the time of the transaction between the Plaintiff and the ○○ Business Office was a false tax invoice; (ii) the Plaintiff paid in full the amount notified of correction without any objection as to the notice of value-added tax correction on the premise that the transaction with the ○○ Business Office was a processed transaction; (iii) the details of the instant tax invoice and the details of the electronic ledger of the ○ Business Office are inconsistent except in part; (iv) the Plaintiff and the ○○ Business Office did not assign the Plaintiff’s transaction number to be input in the device for more than one year, as alleged by the Plaintiff, was difficult to believe that the Plaintiff’s transaction number was not more than one year, and the head of the ○○ Business Office’s 271 minutes prior to the transaction between the Plaintiff and the ○○ Business Office.

(c)

(2) Therefore, the instant disposition that did not deduct the instant purchase amount as necessary expenses is lawful.

3. Conclusion

If so, the plaintiff's claim is without merit, and it is dismissed. It is so decided as per Disposition.