A. The plaintiff (the former trade name: the corporation B) is a corporation that runs the manufacturing and wholesale business of electronic equipment on May 13, 200.

B. As a result of an investigation conducted with respect to the transaction order with the Plaintiff from April 10, 2012 to July 18, 2012, the Defendant confirmed that the Plaintiff made a processing transaction that only receives tax invoices without real transaction as shown in attached Table 1 during the period of value-added tax from February 2, 2008 to February 201.

C. Accordingly, on September 11, 2012, the Defendant notified the Plaintiff of the value-added tax of 407,840 won for the second term portion of 208, value-added tax of 46,681,360 won for the first term portion of 2009, value-added tax of 85,452,840 won for the second term portion of 209, value-added tax of 61,126,750 won for the first term portion of 2010, value-added tax of 163,382,680 won for the second term portion of 201, value-added tax for the second term portion of 201, value-added tax for 1,014,390 won for the second term portion of 201, and corporate tax of 35,214,160 won for the business year of 2010.

(hereinafter referred to as "disposition of dispute"). [Grounds for recognition] The fact that there is no dispute, Gap evidence 1, Gap evidence 2-1 through 8, Eul evidence 1 through 8, Eul evidence 1 through 15, and the purport of the whole pleadings.

2. Determination on this safety defense

A. The Defendant’s assertion is unlawful as to the Defendant’s claim for revocation of the instant “B” disposition among the instant lawsuits, on the following grounds: (a) the period of February 2009; (b) the period of February 1, 2010; and (c) the imposition of value-added tax for the first period of January 201; and (b) the remainder of the disposition did not undergo a pre-trial procedure.

B. However, Article 56(2) of the Framework Act on National Taxes provides that “No administrative litigation against unlawful taxation shall be filed without going through a request for evaluation or a request for adjudication and a decision thereon under this Act.”

In full view of the purport of evidence No. 9, the Plaintiff’s written appeal filed with the Tax Tribunal on December 7, 2012 does not exceed “the imposition of value-added tax for February 2, 2009, February 1, 2010, February 201, and January 201,” subject to appeal.