1. On March 18, 2015, the Defendant’s value-added tax for the second term of 2010 against the Plaintiff was 16,418,630 won, and the first term portion of 2011 against the Plaintiff.

1. Details of the disposition;

A. From June 15, 2005, the Plaintiff is a person who runs the scrap metal business in the trade name of Jinju-si B from Jin-si.

B. The Plaintiff received purchase tax invoices equivalent to KRW 335,526,915 (hereinafter “instant tax invoices”) from the Eas indicated in the following table from the Easia operated by D during the taxable period from 2010 to 1st, 2012, and filed a value-added tax return by deducting the relevant input tax amount from the output tax amount.

Tax invoices (units: won) received by the Plaintiff from the customer name (units) in the aggregate of 94,322,300 82,056,900 106,997,090 52,150,625,526,915

C. Around May 2014, the Defendant: (a) conducted a tax investigation on Ghands operated by F; (b) identified the actual purchasing place of the scrap metal purchased by the Plaintiff as F; and accordingly, (c) denied input tax deduction on the ground that the instant tax invoice issued by D was conducted without a real transaction; and (d) constitutes a false tax invoice.

On March 18, 2015, the Defendant issued a correction and notification of value-added tax to the Plaintiff as follows:

(hereinafter “instant disposition”). Value-added tax (unit of won) imposed on the Plaintiff is 16,418,630 total 13,838,836,930 17,446,930 8,222,060 5,925,620 on February 2, 2011.

E. On June 30, 2015, the Plaintiff filed an appeal against the instant disposition with the Tax Tribunal, but the Director of the Tax Tribunal decided to dismiss the appeal on December 30, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, 3, Eul evidence 3 (including Serial number; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff asserted 1, as indicated in the instant tax invoice, was supplied with the instant tax invoice by purchasing an actual scrap metal from the Ethical world. Therefore, the instant tax invoice is different from the fact.