1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning of the court’s explanation concerning this case is as stated in the reasoning of the judgment of the court of first instance except for dismissal or addition of some contents as follows. Thus, this case is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

The third first sentence of the judgment of the court of first instance refers to “stock company G” as “stock company L”.

The "Plaintiff and A" in the third place of the judgment of the court of first instance shall be considered as "Plaintiff".

Secondly, “B, K, and H’s representative director shall be B, and “B,” shall be added to “B, in-house directors,” in the third place of the judgment of the first instance.

From the 9hhhhhh of the judgment of the first instance court to the 10th heat second one shall be as follows:

“2) In light of the following circumstances, it is reasonable to see that the issue tax invoice is a false tax invoice, and in light of the reasoning of the judgment of the first instance court cited by the first instance court and the evidence submitted, it is reasonable to see that the issue tax invoice is a false tax invoice different from the fact received in the absence of a real transaction; contrary to the evidence No. 77-1 and No. 77-2, it is difficult to believe that some of the items of evidence No. 77-1 and No. 76, and the items of evidence No. 78 through No. 90 (including the provisional number) are insufficient to reverse the recognition, and there is no contrary evidence.

① The Plaintiff, H, D, E, G, I, and F’s representative were controlled and operated by the relevant company, and P was the actual operator of P, and issued and managed the issues and tax invoices directly.

② The Plaintiff et al. appears to have aimed at facilitating the participation in a negotiated contract and competitive bidding, or at creating performance for bank loans by increasing the scale of sales and purchase, by delivering and receiving issues and tax invoices that have no real transactions, and by pretending to have many transaction achievements.

③ The Defendant has made the actual transactions through the instant tax investigation.