1. On February 15, 2016, the Defendant imposed value-added tax for the first term of 2012 on the Plaintiff on February 15, 2016, KRW 744,138, and February 2, 2012.

1. Details of the disposition;

A. From April 12, 2012 to July 5, 2013, the Plaintiff opened and operated D Council Members under the name of Songpa-gu Seoul Metropolitan Government Council Members (hereinafter “instant Council Members”).

B. The Plaintiff was subject to criminal punishment of one year by imprisonment with prison labor for a violation of the Medical Service Act, which committed a medical act against the patient under the name of the instant member with a doctor’s license, notwithstanding the absence of a doctor’s license, and returned to the National Health Insurance Corporation total amount of KRW 242,496,290 according to the decision on recovery of health care benefit costs (hereinafter “the instant recovery decision”).

C. On February 15, 2016, the Defendant: (a) deemed that the medical and health services provided by the Plaintiff to the instant member does not constitute the medical and health services exempt from the value-added tax pursuant to Article 12(1)5 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter the same shall apply); and (b) imposed the value-added tax amount of KRW 74,138,138; (c) value-added tax of KRW 14,072,134; (d) value-added tax of KRW 13,764,674; and (e) value-added tax of KRW 20,553,398; and (e) value-added tax of KRW 18,131,024; and (e) value-added tax of KRW 20,546; and (e) additional tax of KRW 6137,2013.

(hereinafter collectively referred to as "each of the instant dispositions") D.

On April 7, 2016, the Plaintiff filed an appeal with the Director of the Tax Tribunal for adjudication on April 7, 2016, but the appeal was dismissed on June 16, 2016.

[Ground of recognition] Unsatisfy, each entry in Gap evidence 1 to 4 (including each number if there is a satisfy number) and the purport of whole pleadings

2. Whether each of the dispositions of this case is legitimate

(a) as shown in the Attachment of the relevant statutes;

B. Each disposition of this case 1 is subject to value-added tax, which the National Health Insurance Corporation received from the plaintiff according to the decision of recovery of this case, as the medical care benefit cost amounting to 242,496,290.