1. The Defendant imposed global income tax of KRW 23,059,560 on the Plaintiff on August 1, 2014, and imposed global income tax of KRW 23,059,560 on the Plaintiff, 19,429.

1. Details of the disposition;

A. On February 10, 2009, the director of the Gangnam District Tax Office notified the Defendant of the taxation data that the Plaintiff supplied goods worth KRW 380 million in supply value B during the second taxable period of 2004 (hereinafter “instant sales transaction”).

During the period from April 18, 2012 to May 17, 2012, the Defendant conducted an investigation into the part of value-added tax on the Plaintiff. In regard to the actual supplier of goods for the instant sales transaction as C, the Defendant deemed the actual supplier of goods for the instant sales transaction as C and notified the Gangwon-do head of the tax office of taxation data. On May 29, 2012, the Defendant notified the Plaintiff of the results of the tax investigation to

B. Around May 2013, the head of the Gangnam District Tax Office deemed that the Plaintiff was the actual supplier of the instant sales transaction and again notified the Defendant of the taxation data.

C. On August 1, 2014, the Defendant notified the Plaintiff of each determination of KRW 85,215,00 of the value-added tax for the second period of value-added tax (including KRW 3,800,000 for the additional tax on negligent tax returns, KRW 39,615,00 for the additional tax on negligent tax returns, KRW 23,059,560 for the additional tax on negligent tax returns, KRW 23,059,560 for the global income tax for the year 2004 (including KRW 2,091,85 for the additional tax on negligent tax returns, KRW 10

(hereinafter referred to as the "disposition in this case"). 【No dispute exists, Gap evidence Nos. 4 through 8 (including branch numbers; hereinafter the same shall apply), Eul evidence No. 1, and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. 1 Generally, the principle of trust and good faith may apply to a tax authority’s act contrary to a taxpayer’s public opinion when the tax authority expressed a public opinion subject to trust in a tax law relationship. However, in principle, it is based on the premise that the tax authority maintains the circumstances at the time of expressing a public opinion. Therefore, if such circumstances are modified later, it is difficult to deem the taxpayer to be subject to trust.