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

A. From June 13, 2014 to January 2, 2015, the Plaintiff, a business entity that runs a wholesale and retail business of scrap metal in its trade name, issued a tax invoice of KRW 3,927,652,56 (hereinafter “instant tax invoice”) stating that the Plaintiff supplied scrap metal equivalent to KRW 3,927,652,560 in total from June 13, 2014 to December 31, 2014 (hereinafter “instant tax invoice”), and accordingly, filed a return of value-added tax.

B. Around that time, the Plaintiff, the purchaser of the instant tax invoice, paid the value-added tax on the output tax amount indicated in the said tax invoice pursuant to the special case for the purchaser of the copper scrap under Article 106-9(3) of the Restriction of Special Taxation Act.

C. On July 2015, the Commissioner of Busan Regional Tax Office: (a) determined that the Plaintiff issued only the instant tax invoice without real transactions; (b) filed a complaint with the prosecution on the ground that the Plaintiff violated the Punishment of Tax Evaders Act; and (c) notified the Defendant of the pertinent tax data.

3,709,474, 260, 74, 260, 74, 489, 483, 783, 789, 483, 489, 483, 489, 484, 480, 480, 480 for second period 2014

D. On November 9, 2015, the Defendant issued a revised tax invoice for the first and second period of 2014 as indicated below, on the ground that the instant tax invoice was prepared differently from the fact, and notified the Plaintiff of KRW 4,363,560 for the first period of 1,363,560 for the tax invoice unfaithful, and KRW 2,74,189,480 for the second period of 2014.

E. The Plaintiff filed an objection against the foregoing disposition on November 27, 2015, but the Plaintiff was dismissed on December 30, 2015.

F. On May 24, 2016, the Plaintiff filed a claim for correction to the Defendant for refund of KRW 392,765,256 in total of the value-added tax already paid (hereinafter “instant claim for correction”).