On December 1, 2011, the defendant against the rehabilitation debtor A Co., Ltd.

2. Whether the instant disposition is lawful

A. The reasoning of this part of the Plaintiff’s assertion is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the following arguments at the end, and thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

Even if each of the tax invoices of this case constitutes a false tax invoice and is not recognized as a good faith and negligence of A, A filed a return on the tax base of value-added tax without knowing that each of the tax invoices of this case is a false tax invoice, and this does not constitute “the case of underreporting the tax base of value-added tax by an improper means,” and thus, it is unlawful for A to impose the penalty tax for underreporting by the Defendant on A, even though it should be imposed the penalty

(b) Attached Form 1 of relevant Acts and subordinate statutes;

C. The reasons why this court should explain this part of the facts of recognition are as follows: “The closed Dong equivalent to KRW 18,66,794,50 from March 11, 2009 to December 31, 2009, which was 135 times in total,” “The closed Dong amounting to KRW 9,909,180,250 from March 11, 2009 to October 22, 2009,” “The business registration certificate of KRW 11 of Chapter 14, “the business registration certificate”, “the supply price of KRW 320,798.90”, “the supply price of KRW 320,790”, “the supply price of KRW 320,790,90”, “the number 50, 301,” and “the number 50, 509, 50,” respectively, “No. 25, 301,” respectively.