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

A. The Plaintiff is a corporation that operates civil engineering and construction business.

B. The Plaintiff filed a claim for correction with the Defendant on January 10, 2017 [Attached Form 1] on the ground that the extinctive prescription of each claim for construction work (hereinafter referred to as “each claim in the instant case”) stated in the “Priority Claim” has expired, on the grounds that: (a) the Plaintiff provided construction services to the Company B, C, D, and E (hereinafter referred to as “each of the instant transaction companies; (b) the part of “stock company” in the name of each company was omitted); (c) the Plaintiff refused to confirm the details of the supply of goods and services and the fact of the occurrence of bad debts on February 20, 2017. However, the Defendant refused the Plaintiff’s claim for correction on the ground that it is objectively difficult to confirm the fact of the occurrence of bad debts.

(hereinafter “instant disposition”). C.

On May 25, 2017, the Plaintiff filed an appeal with the Tax Tribunal on the instant disposition on May 25, 2017, but was dismissed on September 26, 2017.

[Ground of recognition] Facts without dispute, entry of Gap evidence 1 to 4, and 6 evidence (including a provisional number; hereinafter the same shall apply), the purport of the whole pleadings

2. The Plaintiff asserted that the Plaintiff provided construction works to each of the instant business entities and failed to recover the construction cost. The three-year short-term statute of limitations has expired between February 2, 2011 and February 2012. In particular, each of the instant unpaid claims against C and E constitutes “a claim which cannot be recovered due to the discontinuation of the business.”

Therefore, each of the claims in this case constitutes "a claim which cannot be recovered by loss" under the Value-Added Tax Act, and thus constitutes the subject of a bad debt tax deduction, but the disposition in this case which did not accept the plaintiff's claim for bad debt tax deduction on different premise is unlawful.

3. The entry in the relevant legislation (attached Form 2) is as follows.

4. Determination

A. First, the Plaintiff’s extinctive prescription.