1. The Defendant’s value-added tax amounting to 19,438,210 won for the first term of June 1, 2011 and corporate tax amounting to 2,532 for the year 2011, which was imposed on the Plaintiff on June 1, 2012.

1. The following facts of the disposition may be acknowledged by considering the whole purport of the pleadings in each entry of Gap evidence Nos. 1 through 4, 10, Eul evidence Nos. 1, 2, 3, and Eul evidence Nos. 4-1 and 2:

The Plaintiff is a company that runs wholesale and retail business, such as scrap iron, using 799 as the place of business, in accordance with the Kim Young-si Kim Young-si Kim Young-si, and received one tax invoice (the supply price of KRW 115,101,00, value-added tax of KRW 11,510,100, value-added tax of KRW 11,510,100, and KRW 11,510,100) from the output tax amount, and reported the amount of the value-added tax payable for the first year of 2011, wherein the said input tax amount was included in the deductible expenses.

B. The Busan regional tax office conducted a tax investigation with A from September 15, 201 to November 8, 2011, deeming that the instant tax invoice was a processing tax invoice issued without real transaction, and notified the Defendant of such taxation data.

Based on the foregoing taxation data, the Defendant determined that the supplier, who is a requisite entry item of the instant tax invoice, entered the relevant input tax amount differently from the fact, and subsequently notified the Plaintiff of the correction of KRW 19,438,210 and the additional tax amount of KRW 2,532,220 for the first period of June 1, 201, by allowing the Plaintiff to deduct the relevant input tax amount and to impose the additional tax pursuant to the unwritten evidence for disbursement (hereinafter “instant disposition”).

C. On November 2, 2012, the Plaintiff dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal, and the Tax Tribunal dismissed the Plaintiff’s appeal on June 5, 2013.

2. Whether the instant disposition is lawful

A. At the time of transaction with A, the Plaintiff did not know that he/she constitutes a disguised business operator at the time of transaction with A. ① confirmed the business registration of A and the identity of the representative B, and ② the location of the place of business directly.