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

A. The Plaintiff is a juristic person running oil wholesale retail business from April 1, 2008 to the 284-dong of the wife population in Chungcheongnam-si.

B. In 209, the Plaintiff: (a) received the supply value of KRW 193,709,00 from the No. 200 Date Co., Ltd. (hereinafter “Onboard Energy”); (b) received the supply value of KRW 96,072,00 from the train Energy Co., Ltd. (hereinafter “On Board Energy”); and (c) received the supply value of KRW 738,971,00 from A (hereinafter “A”) during the 2nd taxable period of value-added tax in 2010; and (d) received the supply value of KRW 319,54,000 (hereinafter “the instant tax invoice”) from the Seocho Energy Co., Ltd. (hereinafter “S”) in 2011; and (e) deducted the relevant input tax amount from the output tax amount; and (e) paid the value-added tax by return.

C. On February 1, 2013, the Defendant deemed that the instant tax invoice was a tax invoice written differently from the fact, and thus, deducted the relevant input tax amount from the output tax amount, and notified the Plaintiff of the correction of value-added tax and corporate tax as indicated in the separate sheet (hereinafter “instant disposition”).

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on February 20, 2013, but the Tax Tribunal rendered a decision to dismiss the Plaintiff’s claim on December 30, 2013.

[Ground of recognition] The fact that there is no dispute, Gap's No. 1, 2, Eul's No. 1 (including each number, if any), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff asserts that the disposition of this case is unlawful for the following reasons.

1) The Plaintiff is the Plaintiff’s party to the instant transaction (hereinafter “the instant transaction”).

This case’s tax invoice is actually supplied by the oil supplier.