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All of the plaintiff's claims are dismissed.
Litigation costs shall be borne by the plaintiff.
Reasons
Details of the disposition
A. The Plaintiff is a company established on November 25, 2007 and engaged in the packing and container manufacturing business in Ulsan-gun, Ulsan-gun.
B. In the first and second taxable periods of the value-added tax in 2013, the Plaintiff received 11 copies of purchase tax invoices of KRW 187,122,00 in total from C (hereinafter “C”), and filed a value-added tax return by deducting the input tax amount from the output tax amount, and filed a corporate tax return by appropriating the value of supply as deductible expenses.
The supply value (won) as of the date of the preparation of the taxable period, January 1, 2013, 201, January 30, 2013, 201; the total of 20,420,000 on February 2, 2013, 200; the total of 20,250,070,000 on May 13, 2013, 2013; the total of 109,060,000 on June 30, 2013; the total of 109,967,000,000 on June 13, 2013; the second period of 10,080,000,000 on July 17, 2013; the 070,070,000 on September 10, 2013; the aggregate of 10,1305,108
C. The head of the Ulsan District Tax Office conducted an investigation of value-added tax on C (hereinafter “instant tax investigation”) from May 16, 2016 to June 24, 2016, and confirmed that C filed a return on the aggregate of KRW 2,863,00,000 from 2011 to 2014, and caused the processed sales of KRW 2,080,000 in total to 32 businesses including the Plaintiff by returning the value of supply or receiving value-added tax only. The details indicated below are as follows. C considered to have issued each tax invoice of KRW 109,967,00,00 in total of the value of supply for the first half-year period in 2013 among the tax invoices issued by C to the Plaintiff.
(hereinafter referred to as “each of the instant tax invoices”) D.
Accordingly, the Defendant, as of December 13, 2018, notified the Plaintiff of the correction of KRW 53,62,70 of corporate tax for the year 2013 and KRW 24,248,763 of value-added tax for the year 1, 2013 as of February 11, 2019 (hereinafter “each disposition of this case”). The Defendant, as of February 11, 2019, disposed of KRW 165,167,200, which is equivalent to the proceeds from the transaction of this case, as the bonus of the representative, and notified the change in the amount of income.