1. The plaintiff's appeal against the defendants is dismissed in entirety.

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

purport, purport, and.

1. The reasoning for the court’s explanation as to this case is as stated in the reasoning of the judgment of the first instance except for the addition of the “additional Judgment on the Plaintiff’s assertion” under the following Paragraph (2). Thus, this is cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Additional determination on the Plaintiff’s assertion

A. The Plaintiff did not impose a tax on the Plaintiff from the first day of 2010 until July 12, 2013, which was issued the instant disposition, and thus, the Plaintiff trusted it and declared a value-added tax exemption on the instant service. Since the Plaintiff recognized justifiable grounds for believing that the instant service constitutes the subject of value-added tax exemption, the instant disposition was unlawful in violation of the principle of trust protection. However, even if the Defendants did not impose a value-added tax prior to the instant disposition, it is difficult to view that the Defendants expressed a public opinion that they would not impose value-added tax and additional tax on the Plaintiff, the Plaintiff’s above assertion is without merit.

B. In addition, the Plaintiff asserts that since the instant service constitutes a case where the issuance of the tax invoice is substantially difficult pursuant to Article 25-2 subparagraph 10 of the former Enforcement Rule of the Value-Added Tax Act, the receipt may be issued instead of the tax invoice to the buyer to whom the instant service was supplied, the penalty tax portion on the ground of the non-performance of the tax invoice

Article 25-2 subparag. 10 of the former Enforcement Rule of the Value-Added Tax Act provides that a receipt may be issued in the case of “other businesses similar to subparagraphs 1 through 9, for which the issuance of a tax invoice is impossible or substantially difficult.” However, on the other hand, Article 53(2) of the former Enforcement Decree of the Value-Added Tax Act (tax invoice) (2) of the former Enforcement Decree.