2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

The Defendant’s imposition of value-added tax of KRW 000 (including additional tax), value-added tax of KRW 000 (including additional tax), KRW 000 (including additional tax), KRW 000 (including additional tax), and KRW 000 (including additional tax) of value-added tax of KRW 1, 2013, and KRW 000 (including additional tax) of value-added tax of KRW 2, 2013 for the Plaintiff on December 1, 2015, respectively.

2. Purport of appeal

The same shall apply to the order.

The reasoning for this part of this Court is that the relevant part of the reasoning for the judgment of the court of first instance is the same as that of the relevant part of the reasoning for the judgment of the court of first instance, and thus, this is cited in accordance with Article 8(2)

2. Determination

The reasoning for this part of this Court is that the pertinent part of the reasoning for the judgment of the court of first instance is the same as that of the corresponding part, except that the part from 4 to 10 pages is used as follows. Thus, this Court shall accept it in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

【Revised Contents】

2) The remainder of the tax invoice

Each of the tax invoices of this case (attached Form 2), except for the tax invoices 17 to 25 related to the Nos. 17 through 25, shall also be deemed to constitute a false tax invoice in light of the following circumstances acknowledged by considering the following circumstances, where there is no dispute between the parties, or the whole purport of the arguments in each of the evidence as mentioned above, Gap, 7, 8, 10 through 13, 15, 16, Eul, 6 through 10, and 14 through 33.

(1) As a foreign exporter carries in and keeps in a certain bonded warehouse in the Republic of Korea under his/her responsibility, there is no other security, or there is no additional loan due to a bank's credit limit on corporate operating funds. The number of imported companies which are difficult to lend additional loans shall be utilized as a means of financing.

② Upon receipt of loan funds from the headA, ParkBB, etc., the Plaintiff provided the operator of an enterprise which is difficult to obtain the loan with an intent to sell the exporter, deposit security (40 to 60% of the limit of the credit) necessary for the issuance of the credit from the financial institution. At the same time, the Plaintiff received a prior letter of credit guarantee from the operator of the above enterprise at the time of the loan, and received a prior letter of credit guarantee from the operator of the above enterprise at the time of the loan and received 5 to 10% of the fee from the loan. In other words, the Plaintiff opened a new letter of credit and returned the loan funds in the name of the above enterprise on the date of repayment of the loan funds for 30 days,60 days, 90 days, and 90 days (the date of repayment).

③ As a director of the Plaintiff, the Plaintiff was indicted under thisCC, the Plaintiff’s regular DoD, the Plaintiff’s director Kim E-E and the Plaintiff, on the following facts charged. The above facts charged (attached Form 2) Nos. 3 through 14, 27, and 28 are traded.

(b) have been appointed.

The Defendant, etc. conspired with each other from October 0, 000 to October 0, 000, and in fact, the Plaintiff continued to import Aluminium in 00 times, and had the Plaintiff apply for a loan to issue an import letter of credit in the name of 32 companies, including FF, GG, HH with no experience in importing Aluminium, but with no cash in the name of 32 companies including FF, GG, HH, etc., and paid to the operator on the date of the loan, i.e., cash after deducting 5% or 10% of the import Aluminium price from the import Aluminium price, and 1% of the commission per Broin paid directly to the operator of the business, 30 days, 60 days, and 90 days, and 90 days, without registering the credit business with the competent authority.

(C) From October 0, 000 to October 0, 000, the Plaintiff engaged in the credit business without registering the Plaintiff’s business. ○○ District Court convicted all of the above facts charged. However, the Plaintiff filed an appeal with ○○ District Court 000No0000, and the said court rendered a judgment of innocence in entirety on the following grounds. The Prosecutor appealed with 000Do000 and is currently pending in the final appeal as the Prosecutor appealed with 0000.

“This AA, BB, and E shall, without intent to engage in a normal transaction with the issuing company of the instant L/C through the Plaintiff, merely create appearance such as the normal transaction with Aluminum, using the credit offered by the financial institution, and, upon delegation from the issuing company of the instant L/C, sell Alumin oil stored in a domestic bonded warehouse and prepare cash after receiving directly a transfer of the credit from the issuing company of the instant L/C to the other company, and in the process, Defendant J, J, and HK have introduced the Plaintiff so that the operators of the L/C issuing company of the instant L/C who are difficult to obtain a loan from the financial institution can receive the loan.

The Plaintiff’s act of thisA, BB, and KimE may not be deemed to have engaged in “loan” under Article 2 subparag. 1 of the Act on Registration of Credit Business, etc. and Protection of Finance Users (hereinafter “Credit Business Act”) beyond having committed a self-financial act against the issuing company.

④ According to the premise of each criminal judgment above, entry (attached Form 2) Nos. 3 through 14, 27, and 28

Each actual importer of each transaction is the Plaintiff. The entry of this part of the tax invoice is false to the effect that the Plaintiff purchased Aluminum ingots through each importer and intermediate distributor listed in Nos. 3 through 14, 27, and 28 of the [Attachment 2].

(5) A loan did not proceed with the appeal procedure seeking the revocation of the disposition, even though it was notified of a correction or notification of value-added tax, etc. by the tax authorities (attached Form 2) on the ground that it received a false tax invoice (attached Form 1, 2, 15, 16, 26).

6. In each of the above parts, storage fees for each of the above parts were borne by the Plaintiff, not the importing company or the intermediate distributor, and the delivery of Aluminum aluminium was also made by the Plaintiff.

7) The Plaintiff is the actual importer of each transaction listed in [Attachment 2] according to the Defendant’s statement on October 0, 000 in preparatory documents. Thus, each of the instant tax invoices asserted as a tax invoice different from the fact, but is not implicitly or explicitly disputed.

3) Sub-decisions

Each of the instant tax invoices constitutes a tax invoice different from the facts. Furthermore, in light of the aforementioned circumstances of transactions, it cannot be deemed that the Plaintiff was bona fide and without fault on the part of having received the purchase tax invoices different from the facts. Therefore, the instant disposition based on such premise is lawful, and therefore, the Plaintiff’s claim seeking revocation on the premise that the instant disposition is unlawful is without merit.

2. Conclusion

The plaintiff's claim shall be dismissed as it is without merit, and the judgment of the court of first instance shall be unfair with its conclusion different. The defendant's appeal shall be accepted, and the judgment of the court of first instance shall be revoked,