The Plaintiff is an attorney-at-law who has established and operated a law office (hereinafter referred to as “instant law office”) from January 17, 201 after completing business registration.

The director of the Seoul Regional Tax Office, around October 2013, analyzed the contents of value-added tax return from the first to the second period of 2012 of the pertinent legal office from the date of 2011 to the date of the second period of 2012, notified the Plaintiff that the Plaintiff should submit the submission of the value-added tax evidence return and the revised return from the first to October 25, 2013 on the ground that the suspicion of underreporting the amount of revenue, which is the payment for the provision of legal services, was confirmed.

On November 11, 2013, the Plaintiff filed a revised return on the increase of KRW 512,00,00 from KRW 165,273,065 to KRW 677,273,065 to KRW 512,00,00,00, and paid KRW 55,38,160 to the Defendant accordingly.

As seen later, the Defendant: (a) reduced the tax base of the first period of 2013 from KRW 677,273,065 to KRW 273,502,665 to KRW 403,770,40; (b) decided to refund value-added tax for KRW 34,526,518; and (c) on January 2, 2017, the remaining director of the tax office corrected and notified the Plaintiff of the global income tax of KRW 49,05,560 for the year 2013 to KRW 2012.

As a result of the global income tax integration investigation conducted between September 26, 2016 and October 31, 2016 with respect to the Plaintiff, the head of the tax office having jurisdiction over the global income tax for the year 2013 to October 31, 2016, the underreported amount reported as value-added tax for the first time in 2013 should be attributed to the taxable period from the first to the second time in 2012, and based on the criminal judgment table of the violation of the Attorney-at-Law Act by the staff B, etc. of the pertinent legal office, the amount of under-reported fees and value-added tax received by the client for the actual rehabilitation and bankruptcy of each taxable period (hereinafter “instant service”).