1. The Defendant imposed penalty tax on the Plaintiff on July 8, 2014 in KRW 79,87,336 of the imposition disposition of value-added tax for the first period of 2009.

Basic Facts

On April 9, 1986, the Plaintiff entered into a contract for the construction project of housing site development (hereinafter referred to as the “instant contract”). On November 8, 2006, the Plaintiff was established for the purpose of housing construction project, housing site preparation and supply business, etc., and entered into a contract for the construction project with the Gold Mine Corporation (hereinafter referred to as the “gold Corporation”) with the Seoul Special Metropolitan City Espion Corporation (hereinafter referred to as the “Seoul Special Metropolitan City Ordinance on the Establishment and Operation of SPS Corporation”) to receive the payment of the construction cost for the housing site development project (hereinafter referred to as the “instant project zone”) from Espion Corporation (hereinafter referred to as the “SP Corporation”), and the construction cost was set at 19,593,24,000 won, construction period from November 10, 2006 to May 10, 2009, and the construction cost was set at 1008,000 won including the value-added tax.

The Seoul Special Metropolitan City, which entered into a modified contract following the direction of the change of the value-added tax exemption rate, examined the payment status of value-added tax on the national housing construction service project and the improvement plan thereof. As a result, the national housing construction service exempt from value-added tax includes the portion corresponding to the ratio of the area of the site for national housing construction among the services corresponding to the free supply area, such as roads, parks, facility green areas, etc. provided outside the national housing construction site, and thus, the value-added tax corresponding to this portion is also exempted. On August 2007, 2007, the value-added tax that was paid to E.S. shall be refunded through the request for correction, and in relation to the national housing construction service for which the value

Es. Es. Es. The Corporation shall do so.