A. The Plaintiff acquired a certified public accountant qualification in 193 and operates a “C Accounting Office” in Busan-gu, Busan-gu, as a person who holds a certified tax accountant’s license pursuant to Article 3 subparag. 2 of the former Certified Tax Accountant Act (Amended by Act No. 11209, Jan. 26, 2012).

B. D is an individual entrepreneur engaged in vessel parts manufacturing business (mutual name: E), which is subject to verification of bona fide return pursuant to Article 70-2 of the Income Tax Act in relation to the return of global income tax belonging to the taxable year 2011 and 2012.

(hereinafter referred to as “the instant taxable year and the instant global income tax” in total of the aforementioned taxable years and the respective comprehensive income tax.

The Plaintiff prepared and submitted a “final Return on Tax Base of Global Income Tax and a statement of payment (hereinafter “instant global income tax return”) on behalf of D to the director of the North Busan District Tax Office, the head of the tax office having jurisdiction over D’s place of business, on behalf of D, and submitted a “certificate of bona fide return” (hereinafter “certificate of bona fide return”).

At the time of the preparation of the global income tax return of this case, the Plaintiff ascertains the fact that the Plaintiff received invoices and financial transactions with foreign corporations from D, and D has actually disbursed the amount higher than the amount of income stated in the certificate of import declaration submitted by D to the customs office at the time of import of vessel parts from foreign corporations, and calculated necessary expenses based on the actual income (the difference between the actual income and the certificate of import declaration shall be calculated based on the amount indicated in the attached Table “Difference” column (hereinafter referred to as “Difference”).

b) When citing a specific column of the attached sheet in hereinafter the same shall be as follows: (a) omitted the sign "attached sheet" and immediately refers to the corresponding column); and (b) include in the necessary expenses any payment fee, repair cost, and transportation cost without supporting documents at the request of Doer D (the amount shall be hereinafter referred to as "amount without supporting documents").