2. The costs of lawsuit shall be borne by the Plaintiff.

A. From around 2011, the Plaintiff newly built and sold a house of 160 households and a main complex building of 48 commercial buildings on the ground of the former, Chungcheongnam-gun, Yannam-gun, Seoul, with the business purpose of leasing and selling real estate.

B. The Plaintiff, while selling the above housing and commercial buildings, set the remainder payment period for the second taxable period of value-added tax in 2013 to the buyers at the time of supply for the housing and commercial buildings, issued a tax invoice with the total amount of the sale price and paid value-added tax.

C. From January 6, 2014 to January 25, 2014, the Defendant conducted an investigation into value-added tax on the sale of commercial buildings with the Plaintiff. The Defendant determined that the form of sales contract for 14 commercial buildings among 20 commercial buildings, the sales of which was completed as a result of the investigation, (hereinafter “each of the instant supply contracts”) constitutes the supply of intermediate goods under Article 28(3)3 of the Enforcement Decree of the Value-Added Tax Act, and subparagraph 1 of Article 18 of the Enforcement Rule of the Value-Added Tax Act, and that the Plaintiff’s sales price constitutes the supply of goods under interim payment conditions under Article 28(1)3 of the Enforcement Decree of the Value-Added Tax Act and Article 18 subparag. 1 of the Enforcement Rule of the Value-Added Tax Act. The Plaintiff’s sales price and intermediate payment (10%, intermediate payment 30%, 30%) are different from the fact of supply time; the portion of value-added tax was paid for 20 years to the Plaintiff for 20 years 20.3 years 15 years 2.