1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. The Plaintiff is a business operator who registered his/her business with the trade name “B” on January 2, 2013 and engages in the business intermediary service business.

B. In the second half of 2014, the Plaintiff received a tax invoice of KRW 82.6 million (hereinafter “instant tax invoice”) from C (hereinafter “C”); received KRW 10 million from D (hereinafter “D”); received each tax invoice of KRW 81.3 million in total during the second half of 2014 from Co., Ltd. (hereinafter “D”); and filed a return and payment of value-added tax after deducting the input tax amount related to the pertinent taxable period, in addition to the tax invoice of this case (hereinafter “instant tax invoice”).

C. From April 12, 2016 to May 30, 2016, the head of the Jungyang District Tax Office conducted an investigation related to transaction order with C, and notified taxation data that the tax invoice of this case was issued without the supply of services. The director of the Central District Tax Office of China conducted a tracking investigation of the distribution process of D from April 21, 2016 to August 31, 2016, and notified the taxation data that the tax invoice of this case was issued without the supply of goods.

On November 1, 2017, the Defendant, upon receipt of each of the above notifications, deemed that the Plaintiff received each of the instant tax invoices through the processing transaction, and subsequently notified the Plaintiff of KRW 17,586,220 for the second period of value-added tax (including the additional tax; hereinafter the same shall apply) and KRW 14,417,160 for the second period of 2015, respectively.

(hereinafter “instant disposition”) e.

On January 29, 2018, the Plaintiff filed an objection against the instant disposition with the Defendant, but was dismissed on March 8, 2018, and filed an appeal with the Tax Tribunal on June 11, 2018, but was dismissed on November 16, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 to 3, 8, 11 through 13, 15, 17, and 18 (including various numbers; hereinafter the same shall apply).