1. The Defendant’s value-added tax for the second period of value-added tax for the year 2012, which was imposed on the Plaintiff on September 8, 2016, KRW 47,258,170, and corporate tax for the year 2012, KRW 27,360.

1. Details of the disposition;

A. The Plaintiff is a company that runs gold bullion retail business.

On December 11, 2012, the Plaintiff received a tax invoice of KRW 260,480,000 (hereinafter “instant tax invoice”) from a stock company A (hereinafter “A”).

The Plaintiff issued a tax invoice of KRW 260,713,200 on the same day in the Korea precious MetalM Co., Ltd. (hereinafter referred to as the “Korea precious MetalM”).

B. The Plaintiff reported and paid the value-added tax for the second year of 2012 and corporate tax for the year of 2012 by deducting the input tax amount related to the instant tax invoice from deductible expenses.

C. On September 8, 2016, the Defendant deemed that the Plaintiff received the instant tax invoice from A without a real transaction, and imposed KRW 47,258,170,170, and KRW 27,360,000, the corporate tax for the year 2012 on the Plaintiff.

(hereinafter “Disposition in this case”). 【No dispute exists, entry of Gap 1, 4, and 13 evidence, and the purport of the whole pleadings

2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;

3. Whether the instant disposition is lawful

A. The following facts can be acknowledged according to the statements of evidence Nos. 1 to 3:

1) The flow of gold bullion transactions in accordance with the tax invoice is our precious metal Co., Ltd. (hereinafter “Korea precious metal”).

(2) On May 2013, the Director of the Gangnam District Tax Office conducted an investigation of the data on the precious metal of Korea, and as a result, it became final and conclusive as a processed transaction all of the tax invoices issued in A during the second period of 2012.

On March 2014, the head of the Dongdaemun District Tax Office conducted a data survey on A, and as a result, confirmed A's tax invoices received from Korean precious metals and tax invoices issued by the Plaintiff as a processed transaction.

The defendant, around July 2016, conducted a consolidated investigation of corporate tax against the plaintiff and denied the tax calculation of this case.