1. Revocation of the first instance judgment.

2. The corporate tax attributed to the Plaintiff on July 28, 2017 to the Plaintiff for the business year of 2012.

1. The reason why the court has used this part of the disposition is as follows, except for the case where the second 8 to 12 pages of the judgment of the court of first instance are used as follows. Thus, this part of the reasoning of the judgment of the court of first instance is as stated in Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

“A. B Co., Ltd. (formerly C Co., Ltd.; hereinafter “Nonindicted Co., Ltd.”)

Around June 24, 2004, the purpose of which is to engage in livestock products distribution business, etc. The Defendant: (a) deemed that the non-party company issued and received a false tax invoice of an amount equivalent to KRW 20,868,00,000 without real transactions from 2012 to 2016; and (b) on June 2, 2017, the non-party company imposed corporate tax of KRW 35,236,470 for the business year 2012; (c) corporate tax of KRW 42,984,840 for the business year 2013; (d) corporate tax of KRW 64,285,810 for the business year 2014; and (e) corporate tax of KRW 59,933,620 for the business year 2015; and (e) imposed corporate tax of KRW 8,800,000 for the business year 200 for the business year 20.

) In addition, corporate tax for the business year 2013 includes KRW 44,274,380, corporate tax for the business year 2014, KRW 66,214,380, corporate tax for the business year 2014, KRW 61,731,620, and KRW 9,064,00 for the first year of 2016.

2. Whether the instant disposition is lawful

A. The reason why the court uses this part of the plaintiff's assertion as to this part is 2. A of the reasoning of the judgment of the first instance.

Therefore, in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, this is cited as it is.

B. The attached text of the judgment of the court of first instance is as stated in the relevant statutes.

C. Article 39 Subparag. 2 of the former Framework Act on National Taxes (amended by Act No. 11845, May 28, 2013) of the relevant legal doctrine provides that “The total amount of stocks held or investments made by a shareholder or one limited partner and his/her related parties and prescribed by Presidential Decree shall be the total amount of stocks issued by the relevant legal entity.