1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The Plaintiff’s assertion C subcontracted the construction of earth from the Defendant during the new construction of E, and the Defendant did not pay the Plaintiff value-added tax amounting to KRW 19,145,454 of the tax invoice issued upon request based on the nature of D.

C borrowed money from the Plaintiff, the parent-child of the value-added tax, and transferred the value-added tax claim against the Defendant to the Plaintiff.

The defendant has not received the refund of the value-added tax from the competent tax office but has filed an objection against the plaintiff.

2. Around August 24, 2015, D’s determination as to the cause of the claim was based on the following facts: (a) around 200 million won for the construction work of the E New Construction; (b) during the construction period from August 1, 2015 to October 31, 2015; (c) D entered into an agreement for subcontracting the Defendant from the Defendant (hereinafter “instant contract”); (d) as of August 31, 2015, the supply price of KRW 76 million; (e) value-added 7.6 million; (e) value-added 7 million; (g) value-added 7 million; (g) value-added 7 million; (d) value-added 454; (e) value-added 454; (d) value-added 46; and (e) value-added 454; and (e) value-added 25.145, 2015.