1. Of the judgment of the court of first instance, the imposition of value-added tax for the first and second years of 2012 stated in the separate disposition sheet.

1. Details of the disposition;

A. As a result of conducting a tax investigation into B Co., Ltd. (hereinafter “B”), the Defendant confirmed that: (a) the Plaintiff engaged in wholesale trade business, such as food, etc. from January 201 to February 2014; (b) KRW 121,395,455; (c) KRW 135,57,273; and (d) KRW 85,481,81; (c) KRW 3,756,64; and (d) KRW 3,504,091; and (e) KRW 5,609,00 to February 3, 2013; and (e) KRW 3,609,091; and (e) KRW 13,614,014 to 2014 to 2014; and (e) KRW 385,91; and (e) KRW 384,98 (hereinafter “instant deposit”).

B. When the Plaintiff purchased goods from B, the Defendant estimated the omitted sales amount corresponding to the purchase amount by applying the gross profit ratio of the overall wholesale business of the goods, by deeming that the purchase amount and the sales amount corresponding thereto were omitted due to the payment of the purchase amount and the absence of the tax invoice, etc., as stated in the attached Form of Disposition on Tax.

The Defendant imposed a value-added tax on the Plaintiff by calculating the total sales amount by adding up the sales amount already reported by the Plaintiff and the estimated sales amount by estimation as shown in the attached Form.

(hereinafter referred to as “each disposition of this case” is subject to the imposition of each value-added tax after January 2013 among the imposition dispositions of each value-added tax in the separate sheet of imposition.

On October 12, 2016, the Plaintiff filed an appeal with the Tax Tribunal to revoke the imposition of the above value-added tax.

On February 7, 2017, the Tax Tribunal dismissed a request for a trial on the imposition of value-added tax on the first time in 2011, which was filed after the expiration of the period, on the ground that it is unlawful, and the remaining request for a trial was dismissed.

On May 2, 2017, the Plaintiff filed a lawsuit seeking revocation of the imposition of value-added tax as above.

After that, the defendant shall additionally add 25,956,00 won to the amount omitted in sales for the first period of January 2012.