A. The Plaintiff Company A (hereinafter “Plaintiff Company”) is a corporation whose purpose is to manufacture and sell contact lenses, and Plaintiff B is the representative director of the Plaintiff Company.

C, D, and E (hereinafter collectively referred to as "related business entities") are individual business entities of a sales agency established to sell contact lenses manufactured by the Plaintiff Company.

B. The Plaintiff Company has filed corporate tax on corporate income, and the relevant entrepreneurs have filed global income tax on business income in their respective business names, respectively.

In addition, the value-added tax on each transaction between the plaintiff company and the related business operators has been declared and paid on the basis of related business operators.

C. As a result of the consolidated investigation of corporate tax for the business year from February 8, 2017 to May 23, 2017 with respect to the Plaintiff Company, the commissioner of the Daegu Regional Tax Office under the Defendant-affiliated Regional Tax Office (hereinafter “the instant disposition office”) determined that the Plaintiff Company had the processing purchase and processing personnel expenses. (ii) On the other hand, the relevant business entity falls under the nominal master business entity for the dispersion of the Plaintiff Company, and thus, constitutes the relevant business entity, the amount calculated by subtracting the amount of KRW 1,153,70,708,721 of the total income amount of the relevant business entity’s related business entity’s total income amount of KRW 6,673,536,90 from February 8, 2017 to May 23, 201

B determined that the income should be included in the income of the Plaintiff Company, and notified the Plaintiff Company of the results of the tax investigation on June 13, 2017.

On July 5, 2017, the head of the permanent tax office notified the Plaintiff Company of the total amount of KRW 1,563,513,050 and the total amount of KRW 287,474,250 in the year 1 through 2016, respectively, of the total amount of the corporate tax for the business year 201 to 2016 and the second value-added tax for the year 1 through 2016.

(hereinafter “instant taxation disposition”). E.

On the other hand, on June 26, 2017, the instant disposition agency received tax evasion (Article 3(1) of the Punishment of Tax Evaders Act), violation of the duty to receive tax invoices (Article 10(1) through (3) of the same Act.