Title
Some transaction parties are listed on a false tax invoice, but they cannot be listed on a false tax invoice with respect to other transaction parties.
Summary
Some transaction parties are listed on a false tax invoice, but it is difficult to conclude that other transaction parties are listed on a false tax invoice, and there is no other evidence to acknowledge it differently.
Related statutes
Article 17 of the former Value-Added Tax Act
Cases
2016Guhap64853 Disposition of revocation of Value-Added Tax, etc.
Plaintiff
○○○ Incorporated Company
Defendant
○ Head of tax office
Conclusion of Pleadings
October 17, 2017
Imposition of Judgment
November 14, 2017
Text
1. As to the Plaintiff on June 12, 2015:
(a) Value-added tax (including additional tax) 0,000,000,000 won for the first year of 2012 and the second year of 2013;
Tax (including additional tax) 0,000,000,000,000 for corporate tax for the business year 2012;
Each disposition imposing corporate tax of KRW 0,000,000,000 for the business year 2013;
(b) Disposition of imposition of the value-added tax of KRW 0,000,000,000,000 in the second year of 2012; and
The portion exceeding the source, the portion exceeding KRW 00,000,000 among the imposition disposition of KRW 0,000,000,000 for the first year value-added tax in 2013, and the portion exceeding KRW 00,000,000 among the imposition disposition of KRW 1,200,000 for the first year value-added tax in 2014, shall be revoked, respectively.
2. The plaintiff's remaining claims are dismissed.
3. Of the litigation costs, 70% is assessed against the Plaintiff, and the remainder is assessed against the Defendant, respectively.
Cheong-gu Office
On June 12, 2015, the first value-added tax (including additional tax) for the Plaintiff on June 12, 2012
0,000,000,000, 2012 Value-Added Tax (including additional taxes) for the second period of 2012,00,000,000,000, 1 value-added Tax for the year 2013 (including additional taxes), 0,000,000,000, and 2-added Tax for the second period of 2013 (including additional taxes)
0,000,000,000 won, value-added tax (including additional tax) for the year 2014, 0,000,000 won, and 2012
The imposition of corporate tax of KRW 0,000,000,000, and KRW 0,000,000,000 for the business year 2013, and KRW 00,000,000 for the business year 2014 shall be revoked.
Reasons
1. Details of the imposition;
A. The Plaintiff is a corporation established on September 1, 201 with the purpose of engaging in the wholesale and retail business from 00:00 :00 :00 :00 :00 :00 to 00 ; and ChoA is the representative of the Plaintiff.
나. 원고는 2012년 제1기부터 2014년 제1기까지 부가가치세 과세기간에 별지 1 '공급가액' 기재와 같이 주식회사 BB산업(이하 'BB산업'이라고 한다), 주식회사 CC에너지(이하 'CC에너지'라고 한다), 주식회사 DD메탈(이하 'DD메탈'이라고 한다), 주식회사 EE산업(이하 'EE산업'이라고 한다), FF에이치 주식회사(이하 'FF에이치'라고 한다), 주식회사 GG금속(이하 'GG금속'이라고 한다), 주식회사 HH금속(이하'HH금속'이라고 한다), 주식회사 II스크랩(이하 'II스크랩'이라고 한다), 주식회사 JJ그룹(이하 'JJ그룹'이라고 한다), 주식회사 KK자원(이하'KK자원'이라고 한다), 주식회사 LL메탈(이하 'LL메탈'이라고 한다), 주식회사 MM메탈(이하 'MM메탈'이라고 한다), 주식회사 NN파트너스(이하 'NN파트너스'이라고한다), 주식회사 OO금속(이하 'OO금속'이라고 한다), 주식회사 PP금속(이하 'PP금속'이라고 한다), 주식회사 QQ금속(이하 'QQ금속'이라고 한다), 주식회사 RR(이하 'RR'라고 한다), 주식회사 SS메탈(이하 'SS메탈'이라고 한다), 주식회사 TT산업(이하 'TT산업'이라고 한다), 주식회사 UU자원(이하 'UU자원'이라고 한다), 주식회사 VV메탈(이하 'VV메탈'이라고 한다), 주식회사 WW금속(이하 'WW금속'이라고한다), 주식회사 XX금속(이하 'XX금속'이라고 한다), 주식회사 YY싸이클링(이하 'YY싸이클링'이라고 한다), 주식회사 ZZ테크(이하 'ZZ테크'라고 한다), 주식회사 aa(이하 'aa'이라고 한다), 주식회사 bb메탈(이하 'bb메탈'이라고 한다), cc금속 주식회사(이하 'cc금속'이라고 한다), 주식회사 dd산업(이하 'dd산업'이라고 한다), 주식회사 ee메탈(이하 'ee메탈'이라고 한다), 주식회사 ff(이하 'ff'이라고 한다), 주식회사 gg무역(이하 'gg무역'이라고 한다), 주식회사 hh산업(이하'hh산업'이라고 한다), 주식회사 ii메탈(이하 'ii메탈'이라고 한다), 주식회사 jj스틸(이하 'jj스틸'이라고 한다), 주식회사 kk따움(이하 'kk따움'이라고 한다), ll메탈, 주식회사 mm(이하 'm㎡이라고 한다), 주식회사 nn금속자원(이하 'nn금속자원'이라고 한다), 주식회사 oo월드(이하 'oo월드'라고 한다), 주식회사 pp메탈(이하 'pp메탈'이라고 한다), qq자원, 주식회사 rr금속(이하 'rr금속'이라고 하고, 위와 같이 원고와 거래한 거래처들을 '이 사건 거래처'라고 한다)으로부터 공급가액 합계 000,000,000,000원의 세금계산서(이하 '이 사건 세금계산서'라고 한다)를수취하고, 그에 따른 매입세액을 매출세액에서 공제하여 부가가치세를 신고・납부하였다.
C. However, on June 12, 2015, the Defendant: (a) on June 12, 2015, obtained the instant tax invoice from the Plaintiff as data published.
In other words, the tax investigation that the supplier constitutes a false tax invoice (hereinafter referred to as the "tax investigation of this case").
Tax amount by denying the Plaintiff’s input tax deduction according to the result of the investigation (hereinafter “investigation”).
[Attachment 2] Value-added tax amounting to 0,000,000,000 for the first period of 2012 as indicated in [Attachment 2] List: (i) value-added tax amounting to 0,000,000,000 for the first period of 2012 + value-added tax amounting to 0,000,000,000 for the second period of 2012 + value-added tax amounting to 0,000,000 for the second period of 2012 + value-added tax amounting to 0,000,000,000 for the first year of 2013 + value-added tax amounting to 0,00,000,000 for the first year of 20,000 for the first year of 200,000 for the first year of 20,000 for the first year of 200
Value-added tax amounting to KRW 0,000,000 for the second period of 2 years in 013 (=value-added tax amounting to KRW 0,000,000,000 + Additional tax amounting to KRW 0,000,00,000) and value-added tax amounting to KRW 0,000,000 for the first period of 2014 (=value-added tax amounting to KRW 0,00,000,000 + Additional tax amounting to KRW 00,000,00 for each principal tax and additional tax)
Cases
Value-added tax is imposed for the same reason, 20 additional tax not received due to evidence for the same reason
12. Corporate tax of 0,000,000,000, corporate tax of 2013,00,000,000,000
The corporate tax amount of KRW 00,000,000 in the business year was corrected and notified respectively (hereinafter referred to as "the disposition of imposition of the corporate tax in this case", and in addition to the disposition of imposition of the value-added tax in this case, "each disposition of imposition in this case" is
D. On June 19, 2015, the Plaintiff filed an administrative appeal seeking the revocation of each of the instant dispositions with the Tax Tribunal, but the Tax Tribunal rendered a decision to dismiss the Plaintiff’s claim on March 31, 2016.
[Ground of recognition] Unsatisfy, Gap evidence 1, 2, Eul evidence 1 to 3 (including paper numbers, hereinafter the same
C) Each entry and the purport of the whole pleadings
2. The plaintiff's assertion
Each disposition of this case shall be revoked on the grounds as follows.
A. The Plaintiff, as indicated in the instant tax invoice, purchased copper scrap from the customer of the instant case and was supplied with it, and thus, the instant tax invoice does not constitute a false tax invoice.
B. Even though the company that actually supplied copper scrap to the Plaintiff is not a transaction partner of the instant case, the Plaintiff did not know that the transaction partner of the instant case was not the actual supplier, as it was a party to the instant transaction, such as verifying the business registration certificate, etc. of the instant transaction partner and receiving copper scrap, and fulfilled its duty of care during the process of examination, etc.
C. Even if the Plaintiff reported the tax base by obtaining false certification, the certificate received
Since it cannot be seen that it was false, the tax base under the Framework Act on National Taxes is insufficient in an unjust manner.
The portion of the penalty tax for the imposition of the value-added tax of this case is illegal.
D. From January 1, 2014, the VAT purchaser payment system (the system that pays value-added tax to a designated financial institution without direct payment of value-added tax if the designated financial institution deposits into the designated financial institution without direct payment of value-added tax to the business operator supplied by the supplied business operator) was enforced against the business operator who trades copper scrap, such as the Plaintiff. As such, the Plaintiff deposited all the designated financial institutions’ exclusive accounts without paying the purchase price to 8 transaction parties (k), n metal resources, m, n metal resources, ophones, py, pyths, r metal resources, and r metal), among the transaction parties of the instant case, and thus, the tax invoice against the said transaction parties cannot be deemed to be a false tax invoice. Even if the Plaintiff constitutes a tax invoice different from the facts, the Plaintiff constitutes good faith and negligence as described in the foregoing paragraph (b).
E. From January 7, 2013 to February 15, 2013, the Defendant conducted a tax investigation on the Plaintiff’s tax evasion of value-added tax for the first term portion from January 7, 2012, and subsequently adjusted the increase or decrease of KRW 0,00,000 on April 3, 2013. As such, the instant tax investigation on the part of value-added tax for the first term portion of value-added tax for the same tax item and taxation period, and constitutes a reinvestigation prohibited under Article 81-4(2) of the Framework Act on National Taxes.
3. Related statutes;
Attached 3 is as shown in the "related Acts and subordinate statutes".
4. Determination on the legality of a disposition of imposition
(a) Facts of recognition;
1) Lmera
① On June 22, 2012, AA opened Lmers at the place of business of 00,000,000-00,000 Pakistan, and closed on June 30, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of Lmers shall be as follows:
④ The representative AA stated that a certain R is to be paid and lent a corporate business registration and account to a person, and that only a tax invoice was received and issued without supply of goods or services, and that it was sent by facsimile to a seller, and that he/she prepared a supplementary check after it was sent by facsimile (see subparagraph 4-2, 3 of the evidence No. 4).
⑤ During the above taxable period, Lmers purchased copper scrap amounting to KRW 00,000,000 from Ss resource, which accounts for about KRW 97% of the total purchase amount for the same period (=00,000,000 won / KRW 00,000,000) of Lmers. The representative of Ss Resources, on condition that Lmers receive KRW 1,00,000,000,000 per month, lent the name of the business registration and the business account, and there was no delivery of goods to Lmers, and issued and delivered false tax invoices in accordance with the direction of Lmers, and withdrawn the amount deposited from Lmers and transferred it to Amer (see subparagraph 4-11, 4-1).
(6) On September 12, 2014, KimA was sentenced to the same punishment by the appellate court on January 30, 2015 (case number:00 district court KRW 00,000,000), and on January 30, 2015, the appellate court reversed the judgment of the lower court on September 27, 2015, on the following grounds: (a) despite the fact that there was no fact that he was supplied with copper scrap from s resource or supplied it to Eul, etc. at the time of the preliminary and final return of value added tax for 2 years 2012; and (b) there was no fact that he was supplied with copper scrap or supplied it to Eul, etc., with a false list of tax invoices for each purchaser and trader; and (c) there was a change in the amount of copper scrap to the above judgment of the appellate court on January 30, 2015.
(ii) aa;
① On March 5, 2013, 200:00 000-0, 000 - 000 - 000 - 1 place of business, thisA opened a place of business. The investigator of 00 - visited the place of business from November 15, 2013 to December 2, 2013, but there was no employee other than the representative, but it was confirmed that there was no employee other than the representative, and there was no scrap metal loaded. The 00 - was closed ex officio on December 31, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of a declaration of sale and purchase during the taxable period of a is as follows:
4. The representative of thisA does not have any other income details other than the daily earned income of 2008,000 won, nor does it be sufficient to operate the closed-end business due to lack of cash mobilization ability as a result of property verification.
5. The sole seller of aa is the Plaintiff, and when the price for copper scrap is paid from the Plaintiff to the bank account of Aa, the only seller has come to be paid for ii merth, XX metal, Yyching, gg trade within a short time.
3) Bmers
(1) On August 27, 2013, HongA opened bbmers at the location of 00 military 00 military 00-00 military 00 military 00-0 military 20, but closed on March 4, 2014. The investigator of the 00 regional tax office visited the above location on April 11, 2014, and was confirmed as having been running the existing scrap metal business, but there was no trace that he was running the business in the state of waste. The two countries, the landowner of the bmers, stated that no sub-lease contract for Bmers was prepared, and the adjacent bmers stated that no adjacent bmers were actually transported, purchased, or operated the business (see evidence 6-13, 44, 6-2, 201).
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ The amount of sales and purchase declaration during the tax period of Bmers is as follows:
④ The representative of HongA was a person without a specific residence who mainly lives in the telecom. The employee of bmers stated that the employee did not have any other person than himself/herself, and that the process of issuing electronic tax invoices was well-known (see subparagraph 6-2, 8, and 9).
⑤ Major customers of Bbmers aret metal (purchase amount: KRW 0 billion),u metal (purchase amount: KRW 00 billion), and v resources (purchase amount: KRW 00 billion: KRW 000 billion). The above companies did not pay value-added tax on the transaction partners, such as Bmers, without any data on purchase within the short period of time.
(6) There was no fact that Bmers used water supply from September 2013 to October 2013, where Bmers issued electronic tax invoices (see subparagraph 6-5).
4) MMM malone
① On June 27, 2012, ParkA opened a business with the location of the workplace of 00:00 to 00-00 of 00:0 of 20:00,000, and MMM was closed ex officio on December 31, 2012.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sale and purchase declaration during the taxable period of MMM evasion shall be as follows:
④ From December 22, 2010 to the opening of MM cM cM mp, the representative appears to have no means to purchase high-end waste cms, such as the absence of real estate, as a person who operated the building management business of the trade name, (the sales amount of 00 million won in 2012) of www, which is an employee for eM mbs, and the representative appears to have no means to purchase high-amount waste cms, such as the absence of real estate, and immediately supplied copper scrap to the same selling place as the Plaintiff without transporting it from the transaction partner, and later, he stated that he/she prepared a purchase cmscms to meet the data (the sales cmsp) (see subparagraph 7-2, subparagraph 3, and 4).
⑤ x resources, yy resources, z resources, etc., which are clients, appear to be so-called “explosion business entity,” where purchase tax invoices have not been issued after all processing transactions, while MMMMMM was issued or some of the value-added tax has been paid (see subparagraph 7-1(2) of the evidence No. 7). However, in light of the normal form of operation of the 100 won per 1kg, the amount is very small.
5) Vmera
① On May 7, 2013, 00:00 00 00-0,000 business place was closed on August 13, 2014. The location of the Vmera’s business place has already been registered as a short-term business entity, which is the same business type, and around April 23, 2014, container offices, warehouses, mooringss, mooringss, and PC 2 were confirmed, but the small amount of waste shields and PCs were abandoned in the warehouse, and the small amount of waste shields and PCs were destroyed and damaged, and the PC’s root program was not operated.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ The amount of sales and purchase declaration during the taxable period of Vmers is as follows:
(4) The representative of Cho Jae-A is capable of registering the business of Internet shopping mall and construction interior, and it seems that there is no other income or property owned by him/her and there is no sufficient capability to engage in the high and non-legal distribution business.
⑤ The transaction partner of Vmers stated that he had used the vehicle owned by Vmers when he purchased the vehicle from Bmers (see evidence 8 and No. 6 of this Act). However, according to the register of vehicle of the above vehicle, it was confirmed that the mileage from June 12, 2013 to January 22, 2014 did not have been operated zero.
(6) When examining the details of the issuance of electronic tax invoices, the flow of copper scrap volume shall be ii thalth.
? Vmers ? The order of the Plaintiff is followed, but the tax invoice is reversely followed as follows:
The details of the issuance are confirmed.
(vi) c metal;
① On April 1, 2013, HongA opened a c metal business with 000,000 Dong 00-0 as its place of business, and closed the business on January 31, 2014.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
3. The amount of sales and purchase declaration during the taxable period of c. metal is as follows:
④ The representative RedA does not have the ability to carry on its own property and waste-related business, and does not actually have the ability to carry on the closed-end distribution business in order to make inquiries into the property status. In addition, the representative RedA stated that the actual operator of c metal will be in charge of the representative position and received benefits of KRW 2,50,000 per month from the actual operator of c metal, and that the rightA was engaged in all activities of the entire business (see subparagraph 3 to 4 of the evidence 9).
⑤ Major business partners of c.C. have issued sales tax invoices worth KRW 44.28 billion against c.C., even though the purchase amount is KRW 39.1 million, for c.C., KRW 95% of the total purchase amount as SJ resources ( KRW 44.285 billion / KRW 45.876 million). The SJ resources issued sales tax invoices worth KRW 4.285 million against c.C., even though the purchase amount is KRW 39.1 million.
6. CM received the payment from the same seller and paid it on the day of the SJ resource, and evidence of purchase tax invoices, etc. received two to twenty (20) days after the date of payment, and prepared a purchase tax invoice and a table of accounts by facsimile from the seller.
(vii) BB industry;
(1) On February 6, 2012, AA opened the BB industry with 00:00 00 000 -00 - 00 - place of business as its place of business, and closed on March 18, 2014. BB industry has an actual place of business, and has one vehicle, a boundary, an open site, and an office (2 employees).
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of the BB industry is as follows:
(4) The representative AA does not have any record of engaging in the relevant industry, and the main trading company in the BB industry is deemed to be a so-called so-called 'bomb coal company that did not issue purchase tax invoices with 00 MH metal, DNA, etc.
⑤ According to the banking account of the BB industry (00 bank 00 million won, K bank 000000000, and K bank 0000000000), most of the transactions amount after the cash payment on the day shows the type of transaction in which most of the transactions amount is deposited as the transaction partner.
6. The AA established the BB industry at the proposal of the United StatesA, which is a third village, but the actual operator of the BB industry is the United StatesA, and the actual operator of the BB industry is the actual operator of the BB industry (see, e.g., No. 10-2, No. 10).
(viii)O metal;
① The OMM was established on October 12, 201 at 00:0 00 :00 :00 :00 :00 ;00 ;00 ;000 ; and was closed ex officio on December 19, 2012. At the time of the investigation by the regional tax office on September 11, 2012, the location of the said place of business is unclear as to whether the business was discontinued in the state of closure; at 00 :0 :00 :00 :00 ;00 :00 ; and there was an OMM metal signboard at a container located within the said place of business.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of OM shall be as follows:
④ From 2007, 2008, 2000 fishery, the representative KimA does not confirm the details of the occurrence of specific income other than KRW 0,000,000,00,000, from the daily earned income in 2007, and HM fishery in 201.
⑤ On October 21, 201, the OM had its representative KimB, the location of the place of business of 00:0 :00 :00 :00 :00 :00 :000 :000 ; on February 3, 2012, the representative was corrected from KimB to KimA; on September 20, 2012, the representative was corrected from KimB to 00 :00 :00 :270-4; on October 21, 2011, the lessee of the place of business submitted on October 21, 201 is KimB; on September 20, 201, the lessee of the sub-lease contract submitted on September 20, 201 is KimA; however, the lessee of the sub-lease contract submitted on September 20, 2012 was KimB.
④ On September 12, 2014, KimB was sentenced to a suspended sentence of 00,000,000 won and fine (case number: 00,000,000,000,000 won) in October 30, 2015, and was sentenced to the same sentence in the appellate court (number: 00,000,000,000, but the appellate court reversed the judgment of the court below, and subsequently changed the amount of the above judgment) on January 27, 205 on the following grounds: (a) although there was no fact that he was supplied with copper scrap equivalent to the aggregate amount of 00,000,00 won from the JW resource at the time of the preliminary return of value-added tax on the OM in 2012 at the district court on September 12, 2014; (b) as if he was supplied with the above amount of copper scrap by transaction, he submitted a false list of tax invoices; (c)
7) On the tax invoice of the OM, the transaction price appears to be the type of money withdrawn in cash (the name of a depositor: GaB, KimB, KimB, and KimCC) immediately after the deposit is made in a deposit account (K bank 000 million won00000) in the name of GaB.
9) N Partners
① On August 3, 2012, N Partners opened a business with 00-Gu 0000-00 as its place of business (amended by 00-Gu 00-Gu 000000) and closed on October 31, 2013. At the time of opening a business, the representative is dB, and thereafter ebB, ebB, CC, etc.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of the Npartnership shall be as follows:
④ At the time of investigation, 00 00 -00 - 000 - a place of business, other waste collection companies, SR environment, were in the same place of business, and NN Partners used part of the place of business by subleting. However, there was no facility for storage storage storage or closed wholesale business except for one container.
5. The representative B before the change stated that there was no business experience related to the closed scrap metal wholesale business, the details of the corporation's detailed transactions (on the upper and lower parts of purchased goods), and the representative stated that he worked for the first time during the period of his employment as the representative (see, e.g., evidence 12-3 to 6). After the change, the representative had no experience related to the closed scrap metal wholesale business, and that he started the closed scrap business after hearing only the talk of the above rightB (see, e.g., evidence 12-2 to 6) and did not know about the details of the detailed transactions (referring to the place of lower parts of purchased goods), and that he did not submit the purchase account books, etc. of goods other than the tax invoice.
④ DDR resources, a business partner of Npartnership, were issued only sales tax invoices of KRW 20 billion in 2012, and KRW 000 billion in 2013 in 2013.
7) According to 00 bank accounts, etc., the Npartnership’s principal transaction account, etc., the form of “sales place goods ? issuance of tax invoices ? payment of sales ? payment of purchase ? payment of purchase ? cash withdrawal of transaction funds ? payment of transaction funds.” Unless there are special circumstances, such as: (a) entry into the sales office of the N Partnership into the N Partners from the final measurement time to the cash withdrawal of the DDR resources, which is the customer of the N Partners, into the N Partners’s business; and (b) making cash withdrawal within two to three hours.
8. The IP address of the electronic tax invoice issued by the Npartnership is different from the representative's residence of the PCC, the USM address of the business partner, the respective IP address of the DM logistics company, and some of the IP addresses of the PC located in 00-Gu.
(x)CC energy;
① On October 1, 2009, 00, 00-00, 000, 000 place of business was opened and operated, and closed on March 26, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase for the taxable period ofCC energy shall be as follows:
④ The investigator of a regional tax office visited the workplace on July 11, 2013. However, the status of business closure was already closed, the office’s inside did not have any house, and there was only an empty container such as petroleum additives.
⑤ The representative, who was discharged from the Army on August 1993 and engaged in the business of preventing labor, importing and distributing, etc. without any special occupation, was a person who manufactured and distributed the bareboat around August 2010, and did not have financial ability and expertise for distributing the bareboat consent.
④CC energy leased vacant lots of 000 000 000 000 00 000 00 000 000 000 000 0000 0000 000 0000 0000 000 000 00 000 00 00 000 00 000 00 00 00 00, a representative’s friendly parent-child-child-friendly-child-friendly-child-child-gu CC for the purpose of identifying the place of issuance of electronic tax invoices.
11) PP metal;
① The PP metal was opened on October 10, 2012, and its representative is the B. The place of business is 00:00 00 :00 :00 :00,000 the place of business was closed ex officio on October 10, 2012, which is the opening date by the competent tax office. The place of business was the same as the place of business of AAAmera (hereinafter referred to as “AAmera”) and NewBmera (hereinafter referred to as “newBmera”).
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of the PP metal shall be as follows:
④ The representative of the PP metal and OB stated that KimD was called KimD as KimD and a middle school building, while the actual business owner stated that KimD was Kim Jong (see, e.g., No. 14-2 and No. 3 of the evidence No. 14-2), Park J and GoJ stated to the effect that KimD was a real business owner of AAAAmers in the location of the same business establishment, and that the PP metal was also established (see, e.g., evidence No. 14-3).
⑤ It is confirmed that both PP metal, newBmers, and Internet banking and electronic tax invoices issued by AAmers are identical to the IP addresses. PP metal received processed tax invoices that do not have any real transactions from a bBmers, then traded in the form of receiving purchase tax invoices from a new BBmers.
6) Although the HighJ did not transport the copper scrap, etc. from the new Bmers to the PP metal, it stated that it signed the certificate of confirmation upon the instructions of the OB (referring to the 4th Reference to the evidence No. 14-3).
12) D Industry
① From September 3, 2012, the D industry closed its business on January 11, 2014, and the location of the business was 00,000,000 to 00,000,000,000,000, and again transferred 00,000-0. The representative was YY, Y, YK, and YD in sequence. D industry did not engage in any specific transactions until the second period of 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
3. The amount of sales and purchase declaration during the period of the D industry is as follows:
(4) The representative is a person who has only been engaged in the wholesale and retail business of cosmetic materials or mobile phone retail business in the past and seems to have no history and ability to engage in the business.
⑤t metal, which is a customer of the d industry, is an enterprise that reported only 21.3 billion won at the time of filing a value-added tax return in 2013 and pays value-added tax amounting to 2.1 billion won. In the context of the d industry and the Plaintiff’s sales transaction, the amount transferred from the Plaintiff to the representative of the t metal immediately is transferred from the Plaintiff to the KR.
13) emers
① emers opened on June 18, 201, emers, 00 00 00 -00 -00 - 00 - 00 - as the place of business, and Kim II as the representative of emers, but was subject to ex officio closure on October 28, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the emeral taxable period is as follows:
④ Representatives Kim II had a large number of businesses since 1987, but there was no business history of high and non-ferrous iron industry.
⑤ During the entire period of investigation of emers, the purchase from newCC metal accounts for 49.18 billion won (i.e., KRW 49.18 billion / 49.82 million / 49.94 million / 49.00 million ). According to the CC’s representative KimT, KimT would obtain R from emers representative Kim II, and transferred its name to emers, and emers did not have any tax invoice (see evidence 16-3, No. 16-4, No. 16).
14)ff
① On November 7, 2012, theff started and closed on June 23, 2014. At first, the representative KimCC, a trade name DA, 000 00 00 00 00 00 000 00 00 2 200 (2 2 ) had been changed to HongA, and the representative changed to HongA, the trade name was changed toff, and 00 00 00 00 00 00 00 00 00 00 00 00 00 00.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
④ In the past offf’s place of business, 000-dong 0000-dong 000-0, and 000-00-2, the present place of business, 00-dong 00-dong 00-dong 000-dong 00-dong 00-2, which is the present place of business (on December 4, 2013), it was confirmed that the current place of business is equipped with equipment to carry out water transactions and carries out steel manufacturing works, not non-metallic metal wholesale business.
⑤ Theff remitted most of the amount remitted from a seller to the customer on the day or the following day.
15) Dmers
① Dmers opened on May 1, 2012 and closed on September 30, 2013. At the time of opening the business, Dmers moved to 00,000 and 0-0 (00), but on May 2, 2013, 00,000 and 000-0.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of Dmers shall be as follows:
④ After the relocation of Dmers, there were only one container at a place of business (00 00 - 00 - 000 - 000 -), but it was identified that the actual business was not operated.
⑤ On May 1, 2012, Dmers purchased a large amount of money immediately after the commencement of the business, but, upon issuing tax invoices and paying the amount through the account, deposited in cash on the day of the deposit.
6) Examining the transaction details with the Plaintiff, when preparing a measurement certificate according to the supply, the Plaintiff first prepared a measurement certificate and then issued a measurement certificate, and the price received from the Plaintiff was paid again to the customer.
7) On the other hand, with respect to the transport of the same date and the same vehicle, the time zone for the preparation of an assignment table for the quantity leading to the Plaintiff is confirmed as follows: (a) it is physically impossible to perform any abnormal guidance, such as the transport of other items at the same time as indicated below.
16) g trade;
① The GG trade opened on January 18, 2013 and closed on December 31, 2013. The place of business is 00/0001,00,000.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period ofg trade shall be as follows:
④ The representative of the Gg Trade changed from sss, depthj, Kimmm, and Hej within a short period. He stated that He had engaged in the cargo transport business from 2005 real estate consulting business in 2006 and from 2006 to 2011. At the time of the investigation, she was reported to operate '0 0 o o o o o o o o o o o o o o o o, but he was in the state of suspension of business, and Huj was in the state of suspension of business
⑤ From April 30, 2013 to September 6, 2013, Kimm-m, registered as the representative, was a swimming instructor for 12 years from the date of appointment as the representative of jh, but he stated that he/she acquired jh by introduction from the branch. However, Kimm stated that the source of the purchase fund of copper scrap was not disclosed at all, and that he/she would withdraw in cash from the bank and bring it back to Kimk upon entry of the sales price.
6) As a result of checking the time of measurement in the course of the sales in the jmer of the g trade, there are abnormal circumstances in which the sales in the g trade measured in the g trade from 00:0 to 12:35:00,000, and the time measured in the g trade is 12:00 to 12:35:00,000, in the course of sales from g trade, vehicles and shipping and measuring time are 45:45:0 to 51:00, in the g trade, prior to the measurement from gg trade, the sales in the jmer in the jmer.
17)W metal
① The location of the business place of W metal is 00:0:00 00:00 00,000 ; W metal was opened on September 28, 2012; however, W metal was closed ex officio on October 10, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
④ In the case of 00:00 :00 :00 00 :00 W metal storage reported, only one container and a boundary for the office use. There was no closed-dong, and the representative of W metal k did not actually use the mooring stand (see No. 20 20 No. 4).
⑤ The representative Hank-k of W metal stated that he would receive a salary of KRW 30 million per annum with the introduction of the chair and permitted the registration of the representative, but he was aware that the company engaged in processing transactions and intended to prevent him from doing so (see, e.g., evidence 20-2, 3 through 5).
6. In addition, Hank stated that it was working at the store of W metal, but it did not have any volume on the waste resources or on the root, and that it did not have any photographed a vehicle loaded on the vehicle at a measurementR site designated by the trader and the depository or the seller at each time, and that the product was placed on the side of the vehicle at the place designated by the trader and the store or the seller, and that it did not have any division between the order and the sales comparison with the transaction partner and the direct transaction partner, and that it did not know where the product was loaded (see the evidence 20-2 No. 4 of the evidence No. 20).
18) QQ금속
① QQ금속은 00시 00면 00로 0000-00을 사업장 소재지로 하여 2012. 6. 14. 개업하였고, 2013. 6. 1. 폐업하였다.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ QQ금속의 과세기간 동안 매출・매입 신고액은 아래와 같다.
④ QQ금속의 신고된 사업장에는 컨테이너 1동과 조립식 건물 1채가 있었는데, 실제로는 주식회사 AK자원이 입주해 있었고, QQ금속은 더 이상 사업장으로 사용하지 않고 있었다.
(5) Representative Y has not been engaged in the past business of scrap metal and rain metal industry, and is currently in contact with the National Tax Service, who has no property disclosed in the course of electronic inquiry by the National Tax Service.
⑥ 고YY은 QQ금속 전체 매입의 약 70%를 차지하는 거래처인 NY금속과 JY비철에 대해서도 잘 알지 못한다고 진술하였고, 거래처인 RJ비철자원의 대표 이SS이 2013. 8. 13. 폐동(구리) 실물 거래 없이 2번 정도 QQ금속 사무실에 가서 매출세금계산서만을 작성하여 교부하였다고 진술하였다(을 제21호증 제11쪽 참조).
19) XX metal
① The PM metal was established by the J on August 1, 201 by its representative leJ in order to suspend its business operations. On February 15, 2013, 201, the representative was replaced to SS and the place of business was changed to 00 :00 :00 :00 :00 :00 :00 :00 :00 :00 :00 ; and on September 26, 2013, she voluntarily reported on the closure of business as of September 30, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ The amount of sales and purchase declaration during the taxable period of XX metal is as follows:
④ The ES representative of XX metal stated that she is only the representative under his/her name and actually engaged in the business as Park KK (see, e.g., evidence 22).
⑤ In fact, Park K’s actual representative recognized that he/she is the actual operator of XX metal when conducting a prosecutor’s investigation, he/she stated that the transaction (total of KRW 10.57 billion) with HD companies had been actually purchased from non-data (see evidence 22 No. 3 and 4). However, the relevant evidence is not submitted.
20) Yhething
① On January 15, 2013, YY Ching made business registration with 00 -0 - 00 - 00 - 00 - 00 - 00 - 00 - and 000 - its representative changed from YK to JJ, and closed on September 16, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) During the taxable period of YPing, the reported amount of sales and purchase shall be as follows:
④ On January 15, 2013, as to the location of Yinginging, the location of the office was confirmed as of January 15, 2013, there was a factory room of 000 00 0-00 00 00 00 000 00 000 00 000 00 000 000 000 0000 000 3 201 as of May 9, 2013, there was no office with a view to the night 00 00 00 00 00 00 00 00 00 as of June 20, 2013, there were two 0 00 00 00 00 00 00 000 000 00 - 00 PC as of the place of business registration, and there was no evidence related to the Y’s sales.
YYJ's current representative of YYC is a person with only one-time work experience of a construction company, who has no ability to do so, and seems to have no economic ability to engage in high- and non-legal business as an intangible property, and is currently under joint contact.
④ According to the regional tax office’s investigation of 00 regional tax office with regard to Hh industry, Yh industry, which was the first sales place in 2013, YH industry, the CPU unique number of the CPT branch and YYAC’s electronic tax invoice issuance computer, which is the existing customer of HH industry, was overh industry.
YYPP has received purchase tax invoices during the first period of 2013, and issued sales tax invoices; however, during the second period of 2013, it closed after only issuance of sales tax invoices without purchase.
21) R
① R was the location of 00 00 - 00 -00 -00 - 000 - on October 29, 2012 and was closed on June 30, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase during the period of the RR shall be as follows:
(4) The representative, 00, has no record of engaging in a type of business related to scrap and non-ferrous iron, other than past business history, such as skin, trade, and paint wholesale and retail.
⑤ As a result of financial research on the RR’s account, if advance payment is made from the customer, it has shown the shortest five minutes and thirty minutes, and the customer has shown the form of withdrawing cash on the day or next day.
④ According to the statement of KimS by the cargo driving engineer who has transported the R's volume, KimS stated that the R has not visited the R's workplace once, that the R's workplace was not occupied at all, and that the R's workplace was not occupied at all, and that the R's workplace was moved to a lower-tier vehicle while going through various places, including 00:0:0:00:00:00:00:00:00;00:00:00; and 00:00:0:00; and 200:0:00:00,000).
22) H industry
① On June 30, 2012, the HH industry opened a business with the trade name of 00 00 Do 00 Do 00 Do 00 as its place of business. The HH industry changed its trade name from K to hh industry, and its representative changed from K H to hh industry, and closed its business ex officio on February 28, 2014.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ The reported amount of sale and purchase during the taxable period of Hh industry is as follows:
(4) The representative KimY industry has no working record or business ability in relation to the high and non-ferrous metal industry.
⑤ Upon analyzing the accounts of Hh industry, when making deposits into HH industry accounts at the sales offices, such as BH scrap, the customer shall immediately transfer most of the deposits into the HH industry KimY and TT metal account, and some of the deposits were disbursed as transportation expenses, etc., and the H industry and TT metal were deposited into the H industry immediately after receiving deposits from the H industry.
6) The HH industry, a business partner of the HH industry, immediately withdraws the sales amount from the accounts opened at a point of 000 points in the K Bank, such as HH industry, Co., Ltd., ONSethyl, BH scrap, Co., Ltd., and deliver it to a party with no identity. The HH industry issued only a large amount of sales tax invoice without receipt of the purchase tax invoice and discontinued the industry without permission (the fact that only a large amount of sales tax invoice was issued for a short time without receipt of the purchase tax invoice is the same as the other business partner of the H industry).
7) Examining the details of the financial transaction with the Plaintiff, which is the seller of the HH industry, the transaction price for the purchase tax invoice of KRW 140,000,000 (two copies, 17:00,000,000) received by the Plaintiff from the H industry as of August 26, 2013, was deposited from the Plaintiff’s K Bank account to the 00 bank account in the name of the HH industry on the same day, and without delay, deposited at 16:38,00 in the K Bank account in the name of the representative of the T Metal, and the amount was returned again in cash at 16:42,00 after deposit in the 00 bank account of this K to the 00 bank account of 16:42,00,000.
23) Smers
① At the time of establishment on November 22, 201, SSmere changed the name of the corporation to 00:00 :00 :00 :00 :00 :00 :00 :00 :00 ; the name of the corporation to bJ; and the representative director to bJ II; on October 25, 2012, the name of the corporation to 200 :0 :0 :00 :00 :00 :00 ; and on September 26, 2014, the sales of the representative director to 200 :0 :00 :00 :00 :00 :00 :00 :
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of Smers shall be as follows:
④ The reported business place of SSmers was in the studio-type officetels, and there was no discovery of a signboard, name plate, or mail related to the said corporation, but postal items were sent to the 000 KB (KB).
⑤ Prior to the establishment of SSmer, the representative had no business history for high- and non-retailing wholesale and retail business, and only earned income from 00 banks from 1998 to 2010 and had no history to engage in the related type of business.
6. On the same date on the same date as the purchase and sale certificate of SSmer, the measurement time, the transportation vehicle and the driver are overlapped.
24) ii)
① The location of the place of business was 00 :00 :00 :00 :00 ; the representative was O and operated on January 30, 2012; and closed on April 14, 2014.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the two major taxable periods are as follows:
(4) The representative OO shall not have any record of working in the water-related industry, have not been reported for the last few years, and the property, such as real estate, is not verified.
⑤ Although the representative stated that an OO issued an electronic tax invoice using a computer in the office (see subparagraph 27-3(6) of the evidence No. 27-3), there is no record of payment of office Internet charges, and all 22 IPs are identified by different IPs as a result of tracking the IP on which the electronic tax invoice was issued. In addition, in the case of a transport vehicle, the distance of actual operation is 10,524km, and the distance of actual operation is 941km (see subparagraph 27-1(6)).
6. The representative stated that all of the measurement certificates submitted was prepared in falsity (see No. 27 No. 27 No. 13).
7) In the case of KI resources [the sales amount of KRW 6 billion, KRW 73.4 billion, KRW 73.4% of the sales amount (=6 billion / KRW 8.169 million)] of the principal customer of ii MI, the representative RedJ has no record of engaging in a similar type of business, and it was unclear whether the business was actually carried out because the place of business has not been equipped with a stand-down or an open-down, etc., and ii O stated that O also visited the place of business of KI to check the fact that the KI resources are not equipped with a house, a stand-down, and a rain-in (refer to subparagraph 12 of the evidence No. 27). In addition, the HongJ confirmed that the KJ received the sales amount from its own financial account, and immediately withdrawn the sales amount (RR 1.155 million /8 million), and that an investigation was conducted in the state of contact at the present time.
8. In the case of Vmers, which are the main selling places of iimers, the OO of the representative of iimers stated that the YHmers transported the YHmers using the stude at the time of the waste sales (see No. 27-1, No. 14, and No. 15 of the evidence of this No. 27-1) and submitted measurement certificates and the stude photographs, but the odometer of the vehicle for the period of investigation verified on the vehicle register does not significantly affect the operational records
25) Telecommunication industry
① The TT industry opened its business on May 2, 2012 with the place of business of 00:00 :00 dong 00-0, and changed its place of business to 00 :00 :00 :00 :00 :00.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of the TT industry shall be as follows:
④ The representative entered into a lease agreement for one year with a site for a camping site located at 00,000 :00 :00 :00 on April 27, 2012; and 100,000 won on monthly rent as a condition of payment; however, the total amount for three months was paid to the lessor’s account; however, there was no fact that monthly rent was paid thereafter.
⑤ The location of the TT industry was not a string, and the representative stated that the SS was used along with the extension of the SH metal, which is a second-hand company located in the same lot number, but the business owner of SH metal stated that the business owner of SH metal was almost not deemed to be a non-ferrous metal, which is an object dealt with in the TT industry. In addition, the office had only one book, one computer, and one telephone on a mobile container, but it seems that the dust was not used for a long time due to the storage of dust.
6. The representative stated that SS had no record of engaging in the business related to scrap metal. The above SS used the cell phone (00-000-000-0000) which was opened at the time of the opening of the KR industry by itself, and that it was in excess of the number of times or KimS used for the business prior to the opening of the business (see evidence 28, e.g., evidence 7). However, from the record of the use of the new cell phone (see evidence 28, e.g., evidence 28) of the newly opened cell phone, it was confirmed that the telephone number of the mobile phone number of 00-0000-000-000, which was frequently sent, was the telephone number of YS as its own woman-friendly phone number.
7. The TT industry is a situation in which there is no balance in the passbook of a corporation even though the total sales amount was KRW 12.8 billion by transferring all accounts to the customer immediately after receiving the sales amount from the seller to the passbook.
26) Zines
① The location of the Z theme park’s workplace is 00:00 00 o,000 o, and was started on April 25, 1990. The Z theme park is normally operating at the reported workplace, there are equipment to run the scrap metal wholesale business, such as the house fry and fork knick, at the reported workplace, and employees work normally.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase during the taxable period of the Z theme park shall be as follows:
④ As an enterprise which was merged with and listed by the RR on December 2010 on the RR, the Z the representative ParkJ was a person who has long been dealingd with the scrap metal for long time, but the Z the ZE was made an investment of KRW 400 million from the HongY due to the lack of financial resources after the merger of the Rz. Since the establishment of a separate business establishment of the ZYE, the HongY commenced the wholesale of the red scrap in Korea by newly establishing the separate business establishment of the ZYEE, and made efforts to manage the ZEM as it is suspected that the transactions led by the HongY were transactions (referring to the evidence No. 29, No. 3 and 4 Reference).
⑤ In a normal transaction, the upper, lower, and the upper, and the upper, and the upper, and the upper, lower, and if necessary, the upper, and the upper, and the upper, the upper, lower, and the lower, should be further conducted. However, in the transaction of the Ztech, there were many cases where only the upper, lower, and the lower, were conducted only once without the aforementioned procedure.
6. At the time of the closed scrap metal business, the margin rate of the closed scrap in general is extremely low from 3% to 6% (50 won/ kilograms) or Zzine to 0.6% to 1.3%, and since the general price was determined by the negotiation based on the purchase announcement of large enterprises, the price of the closed scrap metal is at any time changed by item, date, and customer, but if the closed amount per kg, the amount is always fixed to 50 won.
27) UU resources
① UU resource was opened on September 5, 2012 with 00 00 - 00 - 000 - 000 - 0000 - place of business, and closed on September 30, 2013. On May 21, 2013, UU resource investigators visited UU resource’s place of business, and used container’s office as its head office, but did not appear in the form of actual operation of business.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of U.U.S. resources are as follows:
(4) The representative of a physical therapy is only engaged in pharmaceutical business until 2007, and has no record of engaging in a type of business related to scrap and steel.
⑤ U.S. 201,00,000 won from the purchase tax invoice amounting to KRW 5 billion in the amount of KRW 5 billion in the amount of KRW 5 billion in the purchase tax invoice amount of KRW 5 billion in the second half of 2012 (=5 billion in the purchase rate of KRW 99.8% (=5 billion in the amount of KRW 9 billion / 5 billion in the amount of KRW 18 billion in the purchase rate of KRW 18.5 billion in the amount of KRW 1.8 billion in the relevant value-added tax without purchase). Mes KR issued tax invoice 18.15 billion in the second half of 2012 and paid KRW 1.85 billion in the relevant value-added tax.
6) U.S. resource deposits from the seller to the MP, the customer, and the MP has deposited the money in cash on the date of deposit.
28) jSethyl
① Around October 1, 2009, jSethyl was started on the opening of October 1, 2009, and around August 2012, when the representative was changed to Kim J, the sales amount of 2013 increased to KRW 78.1 billion. However, on January 2014, the business was discontinued on February 28, 2014 due to the absence of a place of business.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of jSethyl shall be as follows:
④ The representative Kim J stated that he employed jS K director and Abrate employees when operating jSethyl, but he stated that he was aware of the name, contact address, etc. of Abbrate employees, and that the name of the driver who was the driver who was the driver of Abrate was also ambiguous (see, e.g., evidence No. 31).
⑤ Representative Kim J stated that it was aware of scrap metal business prior to the opening of jSethyl and that it was engaged in scrap metal business through a son and that it started to engage in scrap metal business (see evidence No. 31, e.g., evidence No. 31). In addition, Representative KimJ stated that, at the first statement, jN purchased waste metal at jN was sent to a sales place by classifying it after the lower jN place of business, but later stated that it was later carried out to the sales place or transported to the sales place without carrying out jN (see evidence No. 31, No. 4, and 5).
6) Examining the details of jsethyl account, if the sales amount was received from the seller, the money was transferred from the seller to the customer account within a total amount of money.
7) The KimJ, the representative of the KimJ, stated that the tax invoice was issued using three computers (workplace computers, storage computers, and staff KRN) but its IP addresses were analyzed, and as a result, the tax invoice issued in the name of jS is confirmed to have been issued in the total of 11 computers, and it is not clear that the location of the eight computers, excluding three jSethyl computers, is unclear (see evidence 31 No. 12).
29) E industry;
① The EE industry was closed on February 29, 2012, with its place of business 00:00 dong 000-0, but it was closed on June 30, 2012.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of the EE industry shall be as follows:
④ KimM, K, which was recorded as a shareholder of the EE industry, began to work on the recommendation of SP known to the general public, and stated that the ES had a certificate of seal imprinted and served on the ES, but it had been unaware of its registration as a shareholder (No. 32 No. 2).
⑤ With respect to the transaction partner of the EE industry, KRW 1.533 billion, among the tax invoices received at the first half of 2012, shall be received from the HS, the H metal and KRW 432 million. It was already accused of the fact that 6 transaction partners of KH metal (the amount received as tax invoices KRW 30.837 billion) had already been accused of all as data as a bombane company, etc., the business partner MR metal (the amount received as tax invoices) was confirmed to have not been used as a dry field, that the location of the place of business had not been shaking, and that there was no leased to the landowner, and without purchase, it was confirmed that there was no fact that the land owner has leased it, the sales amount of KRW 21.22 billion was generated in a short period of time, and the amount deposited as sales amount from the receiving company has not been paid in cash, and the value-added tax was not paid in full.
④ The Plaintiff deposited to the EE industry on April 17, 2012 and April 20, 2012 did not issue any tax invoice, etc., nor file any value-added tax return. The EE industry has no prior details even though it owns a fraternity.
30) F. F. H.D.
① On March 29, 2012, F had its place of business closed on September 18, 2012 with the Gyeonggi-do 00 00 00 % 000-0.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) During the F’s taxable period of transfer to F, the reported amount of sale and purchase shall be as follows:
④ The FF’s place of business was a building in a factory. On April 2, 2012, representative KimY stated that FF deposited 00,000 won in cash into the FF’s account on April 2, 2012, the FF borrowed it from the branch, but no relevant evidence was found (No. 33).
⑤ During the first period of 2012, F received a tax invoice of KRW 2 billion from DY resource, KRW 666 million from H resource, and KRW 83 million from H resource. As to the purchase tax invoice received by FF, KimY, the representative of FF value, was unable to produce documentary evidence, such as a supplementary sheet.
④ According to F’s 00 banks (0000000000) and K Bank’s (000000) accounts, if the sales amount is deposited at the sales office, most of the deposits made within one hour were deposited into the accounts of DY resources, etc.
7) As to FF’s sales offices, the representative of FF, KimY, was a document proving the fact of sales, submitted a vehicle photograph and sales measurement certificate, etc., but was unaware of where the actual goods were loaded, and the principal did not present objective data to confirm the actual sales, such as where the contact was made by wire in DY resources, HH resources, and the contact was made by wire in the H, and the principal did not have any objective data to verify the actual sales.
31) GG metal
① GG metal was opened on March 28, 201 and closed on October 27, 2013 with the place of business of 00:00 square meters, 00-00.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase during the taxable period of the GG metal shall be as follows:
④ The GG metal was an enterprise newly opened on March 201, 201, and was KRW 400 million in sales amount, KRW 500 million in sales amount, and KRW 500 million in sales amount, but on January 20, 2012, the representative was changed to BB, and on January 20, 2012, the place of business was changed to KRW 00/32.7 billion in sales amount, KRW 32.6 billion in sales amount, KRW 32.6 billion in sales amount in 2012, KRW 00/300 and KRW 0000,000 in 00.
5. This BB, the representative of the GG metal, was unable to make clear answers to the lease deposit and the source of business income at a place of business with 00:00 00 :00 :00 :00.
6. As a result of the financial transaction inquiry of the GG metal, if the payment is made from the seller, the relevant amount was immediately remitted to the customer, and the said customer most of the said amount was paid in cash.
32) H metal
① HM had started business on April 24, 2009, 000 00 - 000 - 00 - 00 - place of business, and was closed ex officio on October 8, 2012.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase during the taxable period of H metal shall be as follows:
④ Although HM was in fact closed for about two years from the opening of business until September 2011, HM was in fact closed, on September 27, 2011, the main type of business was changed from the existing telecommunications service business to the non-railroad retail business, when the location of the business was 00:00 Dong 000-0 Dong 000 Dong 000 Dong 27, Nov. 22, 2011; and on November 22, 2011, the amount of KRW 00,000 Dong 00 Dong 6.415 billion in 20,000 and KRW 31.29 billion in 20,000 in 201, and KRW 1.81 billion in 2012,000 in 20,000 in 200 and KRW 1.000 in 200 in 2012 had already been used by another corporation ex officio.
(5) From 2001 to H metal establishment, the representative Kim H has a record of working in a company engaged in mining machinery manufacturing business, program development business, computer work development business, software development business, which is irrelevant to the scrap metal business.
6) MR metal (the tax invoice received amount of KRW 15.463 billion, the purchase ratio of KRW 48.3% (=15.4663 billion / 31.96 million)), which is a business partner of HH metal, was confirmed to have been the dry field at the location of the place of business, and there was no rent. It was confirmed that there was no rent, and the sales amount of KRW 21.22 billion occurred during the short-term period without purchase, and immediately withdraw the total amount of the sales amount deposited from the sales place in cash, and did not pay value-added tax.
33) II Scoops
① On March 20, 2012, 201, 200: (a) the place of business was 00 :00 :00 chips closed on August 31, 2012.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
3. The amount of sales and purchase declaration during the taxable period of II ices shall be as follows:
④ DuH, the representative of II Scps, did not operate a non-refit-related business entity or worked in the related business sector, and refused to comply with the investigation by the tax authorities on data.
⑤ While purchasing copper scrap, etc., he received the first tax invoice in 20.2 billion won from HR resources in 20.20 billion won. HR resources were issued only the sales tax invoice without the purchase tax invoice and did not pay value-added tax. At the time, HR resources were not submitted evidentiary documents proving transaction with IIps. The representative of HR resources stated that the amount deposited in the name of the purchase price from II rap, etc. was released from the bank with the name and the name and the name of the non-member (see subparagraph 36 of the evidence No. 36).
34) J Group
① J Group opened its business on October 1, 2009 with 00,000 - 00 - 00 - 00 - 00 -00 - 00 - 00 - 00 - 00 - and closed its business on December 31, 2013.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
③ The amount of declaration of sale and purchase during the period of J Group’s taxation is as follows:
(4) The location of the J Group's place of business is another corporation, and there was no storage or transport vehicle separately registered in addition to the relevant office.
⑤ With respect to the first sale tax invoice of KRW 183,00,000 issued by the J Group to the Plaintiff in 2012, KimJ, the representative of the J Group, did not have any contact with the Plaintiff’s representative, and there was no telephone call, and the supply price adjustment, etc. against the Plaintiff was made by Kim DD, the actual operator operating the AAmera, etc., and the supply price adjustment, etc. against the Plaintiff was continued by the J Group, and the Plaintiff, etc., the seller, etc., was on the part of the transaction parties of the J Group, and did not appear separately from the J Group (see, e.g., evidence 37 No. 9, 10, 14).
35)K Resources
① The place of business of KK resource is 00/00 00 00/00 / 000 / and the place of business of KK resource was closed on August 31, 2009 and was closed on December 31, 2012.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase of KK resources during the taxable period are as follows:
④ On the other hand, the former Y appears to have insufficient career and funds to operate KS resources, as the actual owner of KS resources, as the purchaser and seller of KS resources, and as the actual owner of KS resources, it is reasonable to view KS resources as the actual owner of KS resources as the Gu Y (see, e.g., evidence 38-1 and 2).
⑤ KK자원은 전 대표자인 정JJ이 2009. 8. 31. 00시 00면 00리 000-0에 설립하여 주로 폐지, 고철 등을 매입하여 판매하는 연평균 매출이 6억 7,900만 원(2010년 7억 1,700만 원, 2011년 6억 4,000만 원) 정도인 고물상이었으나, 2012. 3. 27. 대표이사가 정JJ에서 강SS으로 변경된 이후로는 폐지, 고철 이외에 폐동을 대량 취급하여 2012년 반기(1월〜6월) 매출만 200억 원(이 중 폐동 매출은 3월에서 6월까지197억 원)에 달하는 등 매출 상승을 보였다.
36) km
① km’s place of business was 00:00 00 -00 - 00 - January 8, 2014, and was closed ex officio on May 13, 2014.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase during the taxable period of km shall be as follows:
④ At k's workplace, other companies are in operation, and the places reported as storage (00:00:00 00-0,000) are in operation of the same type of business.
⑤ According to the details of km’s financial account, when the money is deposited from the seller to the closed-end transaction account (00 bank account), the money was automatically remitted from the seller to the consolidated account (00 bank account). The money was withdrawn from the account in cash or returned to another consolidated account (K bank account) in cash, and the full amount was withdrawn in cash.
6. KR, a representative of km, reported its business registration and storage as a former taxi engineer upon the request of the branch, and stated that the amount deposited from the Plaintiff, etc. in the name of the purchase price was withdrawn and delivered to the person who is the director in the name of the instructor in the name of the plaintiff and the head of the Kim division (see the evidence No. 39-2 No. 4, 5, 8 through 10).
37) Flicks
① On November 29, 2013, the place of business was 000 Do 0000 Do 0000 Do 000-0, and the business was closed on May 2, 2014. Since the opening of business, 5.67 billion won was issued without purchase.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The amount of sales and purchase declaration during the taxable period of the Rimers shall be as follows:
4. The address of the representative of the Rimers shall be the same as that of the place of business, but the place of business shall have been the incidental warehouse of the farm household in the absence of the closure of the business, and the facilities related to the non-steve business shall not be verified.
5. Thisj has no career in scrap metal business since it was confirmed that it was engaged in carriage of personal cargo and tourist bus articles from 1999 to 2013.
6. The representative stated that it is not possible to present all data on the source of business funds and the customer, and that it cannot be disclosed to the purchaser of copper scrap in relation to the withdrawal of cash immediately after the payment from the seller is deposited (see Section 40-2(6) of the evidence No. 40).
38) m
① On November 3, 2008, the place of business was 00 m- 00 m- m (00 m) and started on February 9, 2015.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sale and purchase during the period of m for a taxable period are as follows:
④ The representative director’s oils owned one bonds, and there is no particular income other than the daily and small business income. The representative director’s oils established a mh-m-m-m-m-m-m-m-m-m-m-m-m-m-h-h-h-h-h-h-, the amount of capital of 200 million won was borne by both h-h-h-h-h-h-h-, and the scrap metal himself/herself, decided to be in charge of both h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-h-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-
⑤ Examining the details of m’s electronic tax invoice issuance, t metal and S, which are transaction partners, were issued after issuing a tax invoice on the Ph metal industry, etc., which is the seller.
6. Tmetallic and S’s logistics, which is a business partner atm, was accused of the National Tax Service by the National Tax Service as data trade because there was no purchase details corresponding to the issuance of sales tax invoices.
39) N metal resources
1 n metal resources are currently in operation on November 6, 2013 with the place of business of 00:00 -00 -00-0 - one place of business.
(2) The details of issuance of the tax invoice for the plaintiff are as follows:
(3) The reported amount of sales and purchase of n metal resources during the taxable period are as follows:
(4) NM resources are corporations established by converting the representative Kimoj into a corporation that is registered as a sole proprietor; no business performance exists for three years after the commencement of the business; and sales and purchase increase during the first period of 2014, as above, immediately after conversion into a corporation.