1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The court's explanation concerning this part of the grounds for the decision of the court of first instance is the same as the pertinent part of the grounds for the decision of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion and the grounds for this court’s explanation concerning each of the above parts are the same as the relevant part of the reasoning of the judgment of the court of first instance, and thus, they are cited by Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

B. Determination 1) Article 17-2(1) of the former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 24359, Feb. 15, 2013; Presidential Decree No. 24359, Feb. 15, 2013; Presidential Decree of the Value-Added Tax Act) provides that a bad debt tax (i.e., bad debt amount x 10/10) may be deducted from the output tax amount in the taxable period where the bad debt becomes final and conclusive, where all or some bad debt of credit sales or other sales claims (referring to those related to the supply of goods or services where a business operator supplies goods on which a value-added tax is levied)

Article 63-2(1) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 24357, Feb. 15, 2013; hereinafter the same shall apply)

(1) Article 19-2(1)5 of the Debtor Rehabilitation and Bankruptcy Act provides that “The Debtor Rehabilitation and Bankruptcy Act (hereinafter “the Debtor Rehabilitation Act”) shall apply as one of the “a claim irrecoverable due to reasons prescribed by Presidential Decree.”

Article 72(2)4-2 of the former Enforcement Decree of the Corporate Tax Act provides that “The amount of stocks, etc. acquired through debt-equity swap shall be the market price at the time of acquisition.”