The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

The grounds of appeal are examined.

1. The main sentence of Article 17-2(1) of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013) provides that “where an entrepreneur supplies goods or services subject to the imposition of value-added tax, all or part of credit sales or other sales claims (referring to those that include value-added tax) in relation to the supply of such goods or services may not be recovered as bad debt, due to the whole or any other reasons prescribed by Presidential Decree,” the main sentence of Article 17-2(1) provides that 10/110 of the amount recoverable as bad debt may be deducted from the output tax amount in the taxable period whereto belongs the date when the bad debt becomes final and conclusive (hereinafter referred to as “ bad debt tax amount”).” The main sentence of paragraph (3) provides that “where an entrepreneur supplied goods or services has the bad debt tax amount deducted from the input tax amount under Article 17 in whole or in part, and the entrepreneur who received the supply becomes final and conclusive before the closure of the business.”

In addition, Article 63-2(1) of the former Enforcement Decree of the Value-Added Tax Act (wholly amended by Presidential Decree No. 24683, Jun. 28, 2013) provides that “any cause deemed bad debt pursuant to Article 19-2(1) of the Enforcement Decree of the Corporate Tax Act” among “any bankruptcy, compulsory execution or other cause prescribed by Presidential Decree” under the main sentence of Article 17-2(1) of the Act refers to “any cause deemed bad debt pursuant to Article 19-2(1) of the Enforcement Decree of the Corporate Tax Act.” Article 1

Any decision to grant authorization for the rehabilitation plan or decision to grant immunity from the court shall be confirmed as impossible.