1. The Defendant imposed a value-added tax of KRW 13,041,740 on the Plaintiff on May 1, 2014.

1. Details of the disposition;

A. B is a person who has engaged in the export business of the excavated machine with the trade name of “C”.

B. B deposited a total of KRW 65,190,000 into a bank account under the Plaintiff’s name from January 1, 2007 to June 31, 2007.

C. During the first taxable period of 2007, the Defendant: (a) deemed that the Plaintiff did not file a return on and pay the value-added tax on KRW 63,880,000 (part of the money deposited from B to the bank account under the Plaintiff’s name as described in the foregoing paragraph (b)); (b) sold the excavated machine; and (c) on May 1, 2014, the Defendant: (a) registered the Plaintiff as a secondhand construction machinery wholesaler; and (b) determined and notified the Plaintiff of the value-added tax of KRW 13,041,740 for the first taxable period of 2007 (i) KRW 638,80,800 for the additional tax of KRW 638,80 for the non-reported additional tax of KRW 638,60 for the non-reported tax of KRW 4,737,340 for late payment on

(hereinafter "Disposition in this case"). 【No dispute exists, Gap evidence Nos. 1, 3, and 8, Eul evidence No. 1, and the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion that the plaintiff introduced a person who intends to dispose of a heavy excavation machine to B to arrange the transaction between the owner of a heavy excavation machine and received fees from B in return for the act of trading between the owner of the heavy excavation machine, and did not sell the heavy excavation machine to B. Thus, the dispositions of this case are unlawful on different premise.

B. According to Article 4(1) of the Enforcement Decree of the Value-Added Tax Act on whether the Plaintiff can be deemed to operate a wholesale business, the classification of the business that supplies goods or services shall be in accordance with the Korean Standard Industrial Classification publicly announced by the Commissioner of the Statistics Korea, barring any special circumstance, barring any special circumstance. “Marketing” under the Korean Standard Industrial Classification prepared and publicly announced by the Commissioner of the Statistics Korea pursuant to Article 22(1) of the Statistics Act is selling to retailers with the ownership of the goods.