1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. From February 12, 2015 to May 20, 2015, the director of the Seoul Regional Tax Office: (a) conducted a tax investigation on the Plaintiff and STCF; and (b) notified the Defendant of taxation data that the Plaintiff constitutes the business place for the use of the name of STCF.

B. Accordingly, on June 10, 2015, the Defendant denied Plaintiff’s sales and purchase, and deemed the tax invoice received by the Plaintiff as a false tax invoice, and imposed a disposition of imposition of value-added tax of KRW 26,695,840 for the second term portion of the year 2012 on the Plaintiff, KRW 11,226,040 for the first term portion of the value-added tax in 2013, KRW 26,495,60 for the second term portion of the value-added tax in 2013, KRW 19,075,270 for the first term portion of the value-added tax in 2014, and KRW 9,645,110 for the second term portion of the value-added tax in 2014, the pertinent tax amount was refunded to the Plaintiff.

C. On September 10, 2015, the Plaintiff filed a request for a trial with the Tax Tribunal, but was dismissed on September 29, 2017, and the written decision on the trial (hereinafter “instant written decision”) was served on the Plaintiff’s agent on October 11, 2017.

[Reasons for Recognition] Unsatisfy, Gap evidence 1 to 5-4, Eul evidence 1 and 2, the purport of the whole pleadings

2. Determination on this safety defense

A. Since the Defendant’s instant lawsuit was filed more than 90 days after the Plaintiff was served with the written decision on the instant judgment, it is unlawful as the period for filing the instant lawsuit has expired.

(b) Administrative litigation on judgment shall be instituted within 90 days after the decision on a request for examination by the National Tax Service, a request for adjudgment by the Tax Tribunal, or a request for examination by the Board of Audit and Inspection;

(Article 56(2) and (3) of the Framework Act on National Taxes. The claimant may appoint a certified tax accountant as his agent for a request for adjudgment, and his agent may perform any act concerning such request or request on his behalf.

(b).