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

A. On May 31, 201 and December 5, 2011, the Plaintiff: (a) was a person engaged in wholesale and retail business, export and import business of agricultural products; and (b) was imported from the Daiyu Conde Co. Ltd. (hereinafter “instant exporter”); and (c) the Plaintiff filed an import declaration on September 23, 201 through December 14, 201, on the part of China (hereinafter “each of the instant goods”); (d) the Plaintiff filed an import declaration on September 23, 201 through December 14, 201, on the part of China, and filed a declaration on the transaction price of USD 240 per ton.

B. As a result of the prior tax examination on the Plaintiff’s above import declaration, the Defendant denied the Plaintiff’s filing price on the grounds that there is a significant difference between the transaction price of the goods of the same kind and quality or similar goods, and that the Plaintiff failed to submit materials to prove that the filing price is identical to the fact. As to the instant goods, Article 32 of the former Customs Act (amended by Act No. 11121, Dec. 31, 201; hereinafter “Customs Act”) and Article 35 of the Customs Act as to the instant goods, Article 1, 210 U.S. dollars for the instant goods, 2, and 3 goods, 1,10 U.S. dollars for the instant goods, 2, and 3 goods, respectively, and notified the Plaintiff of KRW 36,043,60 based on the difference between the filing price and the dutiable value. < Amended by Act No. 11486, Apr. 10, 2012>

C. The Plaintiff appealed and filed an appeal with the Tax Tribunal on May 17, 2012, but was dismissed on February 1, 2013.

On the other hand, the Defendant, on February 3, 2014, found that the goods of this case Nos. 2 and 3, which were recognized as the taxation declaration price on the adjacent date on the date of entry, was discovered.