1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance cited by the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except to dismiss or add the corresponding part of the judgment of the court of first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 42

【The part to be removed or added 【The business account” in 2 pages 6 is the business account (FF of the new bank; hereinafter “instant account”).

The following shall be added to the 3rd 14th 14th 14th 14th :

【Determination as to whether such presumption can be made at the time ought to be made by comprehensively taking account of all the circumstances as to the amount deposited into the relevant financial institution account, including whether the relevant financial institution account has been used as a principal deposit management account for the sales of taxable goods or revenues, the date of deposit, the other party, and the amount, etc.; the weight of sales or import-related transactions in the transaction in question; the possibility of mixing funds for other purposes, not sales or revenues, and the degree thereof (see, e.g., Supreme Court Decisions 2012Du7769, Jun. 23, 2015; 2016Du1035, Jun. 29, 2017).

2) In full view of the following circumstances, the instant money deposited in the instant account may be presumed to constitute sales, and the evidence presented by the Plaintiff alone is insufficient to reverse the said money, taking account of the absence of dispute between the parties, or the following circumstances revealed by adding up the entire purport of the pleadings to the respective statements in Gap evidence Nos. 4, 7 through 11, and Eul evidence Nos. 1, 2, 7 through 9 (including each number number; hereinafter the same shall apply).

Ultimately, the instant disposition is lawful on the premise that the instant money constitutes an omission in sales subject to value-added tax by a Contracting State.

① The instant account is opened by the Plaintiff’s Contracting State.