1. Revocation of the first instance judgment.

2. Among the instant lawsuit, value-added tax for the second term of 2014 and value-added tax for the first term of 2015.

1. Details of the disposition;

A. From October 10, 2014, the Plaintiff is engaged in wholesale and retail business, such as scrap iron and steel scoops, with the trade name “C” from scood City B.

In relation to the above workplace, the Plaintiff reported and paid the value-added tax for the second term of 2014 and the value-added tax for the first term of 2015 as follows.

(unit: 20,348,8412, 392, 392, 803, 60, 235, 373, 907 21,250,218, 340, 218, 340, 2425, 286, 585 15,025,066, 289,410, 228, 628, 941 payable for the second term portion in 2014, 220,348, 8412, 392, 893, 35, 800, 61, 600, 600, 1,235, 657, 251, 2361, 24636, 265, 294, 26365, 261, 26364

B. After conducting a tax investigation on the Plaintiff’s workplace from April 2015, the director of the Central Regional Tax Office confirmed that the Plaintiff issued a false sales tax invoice without any actual transaction during the taxable period of two years in 2014 and January 2015.

Based on this, the Defendant issued a decision to correct the value-added tax (hereinafter “decision to correct the instant reduction”) that reduces KRW 17,768,20,620 from the total amount of the supply value for the second term in 2014, and the total amount of the supply value for the first term in 2015, which reduces KRW 1,776,820 from the total amount of the output tax for the second term in 2014, and KRW 1,76,820,962 from the output tax for the first term in 20

C. On March 23, 2016, the Plaintiff filed an application for rectification with the Defendant to seek refund of KRW 3,358,598,480 (hereinafter “instant application for rectification”) for value-added tax for the second term portion of KRW 1,233,576,650, and the first term portion of KRW 2,125,021,830 for the first term portion of KRW 2,358,598,480 for the first term portion of KRW 2015 (hereinafter “instant application for rectification”), but the Defendant rejected the application on May 31, 2016.

(hereinafter “instant disposition”) D.

On July 11, 2016, the Plaintiff filed an appeal with the Tax Tribunal. However, the Tax Tribunal prescribed the special provisions of this case on November 30, 2016.