The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Article 45(1) main text of the Value-Added Tax Act provides that "Where an entrepreneur supplies goods or services subject to value-added tax, and is unable to recover as bad debt due to the bankruptcy or compulsory execution of a person who receives the supply of all or any other sales claims (referring to those that include value-added tax) or other causes prescribed by Presidential Decree, 10/110 of the irrecoverable amount due to bad debt (hereinafter referred to as " bad debt tax amount") may be subtracted from the output tax amount in the taxable period whereto belongs the date when the bad debt becomes final and conclusive, from the bad debt amount in the output tax amount in the taxable period whereto belongs the date when the bad debt becomes final and conclusive. In applying paragraphs (1) and (2), where the entrepreneur supplied goods or services deducts all or part of the bad debt tax amount equivalent to the bad debt tax amount as the input tax amount under Article 38 before the entrepreneur closes the bad debt tax amount, the entrepreneur supplied with such goods or services shall deduct the relevant bad debt tax amount from his/her input

In addition, Article 87(1) of the Enforcement Decree of the Value-Added Tax Act provides for one of the "any bankruptcy and compulsory execution under the main sentence of Article 45(1) of the Act and other grounds prescribed by Presidential Decree" as one of the "any grounds for recognition of bad debt pursuant to Article 19-2(1) of the Enforcement Decree of the Corporate Tax Act." Article 19-2(1)5 of the Enforcement Decree of the Corporate Tax Act provides for "a claim confirmed to be impossible to be recovered due to a decision on authorization for rehabilitation plan under the Debtor Rehabilitation and Bankruptcy Act (hereinafter

Meanwhile, when it is decided to grant authorization for the rehabilitation plan, the rights of rehabilitation creditors, rehabilitation secured creditors, shareholders and equity right holders are modified according to the rehabilitation plan (Article 252(1) of the Debtor Rehabilitation