1. Of the instant lawsuit, the part regarding the imposition of value-added tax on 1 January 201 as indicated in the separate disposition sheet.

1. As a result of conducting a tax investigation on Company B (hereinafter “B”), manufacturing companies, including vehicle parts, etc. (hereinafter “B”), the Defendant: (a) deposited the Plaintiff’s total amount of KRW 121,395,455 won from 2011 to 2014 with B’s name account from January 1, 2011; (b) KRW 135,57,273; and (c) KRW 85,481,81,81,818; (d) KRW 3,756,64, 2012; and (e) KRW 3,504,091 won in January 3, 2013; and (e) KRW 5,609,091 won in February 5, 2013; and (e) KRW 135,614,981; and (e) KRW 398,985 won in the instant case (hereinafter “the instant amount”).

The Defendant estimated the omitted purchase amount by applying the total profit ratio of the wholesale business in the comprehensive sale of the goods, and estimated the omitted sales amount corresponding to the purchase amount by applying the total profit ratio of the wholesale business in the comprehensive sale of the goods, and imposed each value-added tax on the Plaintiff as stated in the attached Form No. 1, considering that the Plaintiff paid the purchase amount of this case to the purchase price and did not receive the tax invoice.

In the imposition of value-added tax in the separate sheet of imposition of each value-added tax, the remainder except for the imposition of value-added tax for 1 January 201 shall be referred to as "each of the instant dispositions."

(i) [Evidences Nos. 2 and 3, Eul evidence No. 1, and the purport of the whole pleadings for recognition.]

2. The Defendant asserts that the part of the instant lawsuit regarding the imposition of value-added tax on January 201, 201, among the instant lawsuit, is unlawful since it did not go through legitimate pre-trial procedures after the period for filing a petition for trial expires.

According to Articles 56(2), 61(1), and 68(1) of the former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same), an administrative litigation against a disposition under tax-related Acts may not be filed without undergoing a request for examination or adjudgment under the Framework Act on National Taxes and a decision thereon.