1. On September 1, 2011, the Defendant imposed an additional tax of KRW 79,58,525 on the Plaintiff for the second period of value-added tax in 2010.

1. Details of the disposition;

A. The Plaintiff, a corporation engaged in wholesale and retail business, such as NAS, received four copies of the purchase tax invoices of KRW 1,841,007,673 (hereinafter “purchase tax invoices of this case”) in the 2010 taxable period of the second value-added tax as listed in the table below, and issued four copies of the sales tax invoices of KRW 1,927,972,363 (hereinafter “instant sales tax invoices”) to the small and medium enterprise distribution center of the company (hereinafter “small and Medium enterprise distribution center”). After issuing four copies of the sales tax invoices of KRW 1,927,972,363 (hereinafter “instant sales tax invoices”), the Plaintiff reported and paid the remainder of the tax invoices other than the sales tax invoices of November 30, 2010, as listed in the table below.

(2) The following facts are revealed: (a) the supply value on August 1, 2010 on August 2, 2010 on the receipt date of the purchase tax invoice and the sales tax invoice; (b) the supply value on the receipt date of the sales tax invoice and the receipt date of the sales tax invoice; (c) the supply value on the receipt date of the purchase tax invoice and the receipt date of the sales tax invoice and the receipt date of the tax invoice; (d) 457,129, 964, 478, 720, 909, Sept. 7, 2010; (d) 457,29, 709, 709, 478, 478, 455 on September 29, 2010; and (e) 459, 390, 364, 364, 2010; (e) 108, 167, 184, 2017

B. From May 17, 2011 to August 24, 2011, the head of Seoul Regional Tax Office conducted an investigation of value-added tax on the Plaintiff and related enterprises, etc., and notified the Defendant of the taxation data by deeming the instant tax invoice received by the Plaintiff as a processing tax invoice.

C. Accordingly, the Defendant issued a revised notice of KRW 94,487,960 of the value-added tax for September 1, 2010 to the Plaintiff on September 1, 201, on the following grounds: (a) both the output tax amount and the input tax amount under the instant tax invoice are reduced; and (b) applying the additional tax on the nonperformance of the tax invoice to receive the instant tax invoice; and (c) details of the correction are as follows; and (d) penalty tax