1. The Defendant’s imposition of value-added tax of KRW 96,446,880 on January 7, 2013 against the Plaintiff on January 7, 2013, 80, among the imposition disposition of KRW 96,46,880 on the Plaintiff.

1. Details of the disposition;

A. From July 10, 2006, the Plaintiff is a business operator who operated a gas station in C in Sungsung City B.

B. The Plaintiff received each tax invoice of KRW 3,103,421,00 (hereinafter “instant tax invoice”) from nine companies, including Dae Petroleum Co., Ltd. (hereinafter “the instant transaction partner,” and omitted from the company name) as listed in the table below during the first taxable period of the value added tax in 2010 to 2012, and filed and paid the value-added tax including the input tax amount equivalent to the value of supply subject to deduction.

E F G D D

C. On January 7, 2013, the Defendant denied the input tax deduction by deeming the instant tax invoice as the processed tax invoice, and on January 7, 2013, included the Plaintiff the value-added tax of KRW 96,446,880 (including the penalty tax for unfair underreporting), the value-added tax of KRW 132,252,410 (including the penalty tax for unfair underreporting amount of KRW 29,169,040), the value-added tax of KRW 141,257,340 (including the penalty tax for unfair underreporting amount of KRW 32,111,240), the value-added tax of KRW 120,15,180 (including the penalty tax for unlawful underreporting amount of KRW 28,213,720), and the additional tax for each underreporting amount of value-added tax of KRW 132,257,340 (including the penalty tax for unlawful underreporting amount of KRW 120,1579,2979).

(hereinafter “instant disposition”) D.

On April 5, 2013, the Plaintiff appealed to the Tax Tribunal, but was dismissed on November 22, 2013.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1 and 2 (including each number), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff asserts that the disposition of this case is unlawful for the following reasons.

1) Since the Plaintiff was actually supplied with oil by the instant transaction party and received the instant tax invoice, it cannot be deemed that the instant tax invoice was a false tax invoice. 2) Even if the actual supplier of oil, the instant transaction party is the oil supplier.