1. On February 1, 2014, the Defendant reverted value-added tax of 132,063,840 won and 2009 to the Plaintiff on February 1, 201.

1. The total value of purchase of tax invoices by transaction partners during the taxable period prior to the disposition, No. 1 B 47825,399,998, and the total amount of 30 547,399,336, 2010, 1,372, 79,334;

A. On July 17, 2008, the Plaintiff was established for the purpose of engaging in the export and import business of used cars. From the first half of the year 2009 to the second half of the value-added tax in 2010, the Plaintiff received a tax invoice of KRW 1,372,79,334 (=825,39,98,99,547,399,336) from B and C (hereinafter “instant tax invoice”) as listed in the table below in the taxable period of the second half of the value-added tax in 2010, and paid the value-added tax by deducting the input tax amount from the output tax amount.

B. However, on February 1, 2014, the Defendant: (a) calculated the amount of taxation by denying the deduction of the pertinent input tax amount on the grounds that the instant tax invoice constitutes a false tax invoice without a real transaction; (b) notified the Plaintiff of KRW 132,063,840, and value-added tax of KRW 105,69,697,070 for the second period of 2010; and (c) at the same time, deemed that the Plaintiff did not receive the tax invoice under Article 16 of the Value-Added Tax Act even if he was supplied with goods by the business operator; and (d) accordingly, the Defendant corrected and notified the Plaintiff of KRW 16,507,980 for the business year 209, KRW 10,947,960 for the corporate tax belonging to the business year 2010, respectively.

(hereinafter referred to as “each of the instant dispositions” by referring to the imposition of value-added tax and corporate tax as above.

On May 1, 2014, the Plaintiff dissatisfied with each of the instant dispositions and filed an appeal on May 1, 2014, but the Tax Tribunal rendered a decision to dismiss the Plaintiff’s claim on November 17, 2015.

On the other hand, on September 24, 2013, the Plaintiff was closed ex officio.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 to 5 (including each number in the case of additional statements), the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate