A. The Plaintiff is a person who operates the clothing wholesale business under the trade name of D, and Defendant B is a person who actually operates the above D.

Defendant C is the representative director of E Co., Ltd. (hereinafter “E”).

B. The Plaintiff imported goods from China and supplied them to E, and the director of the Seoul Regional Tax Office conducted a tax investigation on the Plaintiff from July 9, 2009 to September 9, 2009. The Plaintiff issued processed sales tax invoices equivalent to KRW 6,647,00,00 to 208, and filed an accusation of KRW 7,123,00,000 from 25 companies, such as F, etc. 208, KRW 208, KRW 39, KRW 2086, KRW 2086, KRW 39, KRW 2086, KRW 209, KRW 2086, KRW 2086, KRW 1696, KRW 2086, KRW 39, KRW 240, KRW 2096, KRW 2086, KRW 2096, KRW 16, KRW 2096, KRW 296, KRW 2096, KRW 296, KRW 2008, KRW 196,684,68606.

C. Meanwhile, the Plaintiff did not include part of the overseas processing fees paid in cash in the import declaration price, but filed an application for revision of the customs duty base after filing an import declaration. On February 4, 2010, the Plaintiff paid KRW 714,813,000 for customs duties, value-added taxes and additional duties, which was subsequently borrowed from E.

1) The Plaintiff filed a tax appeal with the Tax Tribunal regarding the disposition under the above sub-paragraph (b). At the time, ① whether the Plaintiff received 3,528,843,00 won (the first amount in dispute) supplied to E as false sales, ② The tax base amount on the import tax invoice received by the Plaintiff from the customs collector is deemed as purchase amount and deemed as necessary expenses.