1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On October 1, 2017, the Plaintiff completed business registration with its trade name “B”, “B”, and “B” location as “Macheon-si and one parcel,” “business name,” and “non-residential building.”

B. On January 25, 2018, the Plaintiff filed a final return on value-added tax (hereinafter “instant return”) seeking refund of KRW 19,854,528, using the output tax amount as KRW 0 and the input tax amount as KRW 19,854,528, when filing a return on value-added tax for the said B on February 25, 2017.

C. The Defendant: (a) deemed that the remainder of KRW 19,836,927, excluding KRW 17,601, out of the above input tax amount of KRW 19,854,528, excluding the other input tax amount of KRW 17,601, is the purchase by a false tax invoice; (b) refused to refund pursuant to Article 39(1)2 of the Value-Added Tax Act; (c) imposed additional tax on excess refund amount of KRW 1,983,692 (i.e., KRW 19,836,927 x KRW 10/100, and KRW 10/100) pursuant to Article 47-3(1)2 of the Framework Act on National Taxes (hereinafter “instant disposition”).

On July 2, 2018, the Plaintiff dissatisfied with the instant disposition and filed a request for examination with the Commissioner of the National Tax Service, but the Commissioner of the National Tax Service dismissed the request for examination on October 16, 2018.

[Reasons for Recognition] Unsatisfy, Gap evidence 1, 2, Eul evidence 1 and 13, the purport of the whole pleadings

2. Determination on the legitimacy of the instant disposition

A. The Plaintiff asserted that the Plaintiff requested E to arrange construction companies and pay construction costs in connection with the construction of Class II neighborhood living facilities (hereinafter “instant building”) of Category D and Category C ground-based neighborhood living facilities (hereinafter “instant building”). The Plaintiff paid KRW 228,700,000 received from the Plaintiff, etc. as construction costs to the construction company, etc., and the Plaintiff received tax invoices from each contractor who received construction costs through E.

Therefore, each tax invoice is consistent with the substance of the transaction.