1. All appeals by the Defendants are dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

1.

1. The reasoning of the court's explanation concerning this case is as stated in the judgment of the court of first instance except for addition or dismissal as stated in paragraph (2) below. Thus, it is acceptable to accept this as it is in accordance with the main sentence of Article 420 of the Civil Procedure Act.

2. The addition or height of the part of the judgment of the first instance shall be the sum of KRW 59,508,000 (including value added tax) in Form 11 of the judgment of the second instance.

The following details shall be added at the lower end of the second judgment of the first instance:

In addition, even though Defendant B issued a tax invoice and issued it to Defendant B so that the value-added tax can be refunded if it pays the above goods to the Plaintiff, Defendant B does not have the obligation to pay the value-added tax even because the Plaintiff merely issued the tax invoice to Defendant B.

However, according to Articles 32(1) and 34(1) of the Value-Added Tax Act, when an entrepreneur supplies goods or services, he, in principle, has the obligation to issue a tax invoice to a person who receives the goods or services at the time of supply, and it is difficult to view that he/she has the obligation to issue a multiple tax invoice to a joint guarantor of the supplier. Furthermore, the Plaintiff agreed to issue

In light of the absence of evidence to prove that there is a duty to provide or deliver, Defendant B’s above assertion on a different premise is rejected.

3. In conclusion, the judgment of the first instance is legitimate, and all appeals by the Defendants are dismissed as they are without merit. It is so decided as per Disposition.