1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The debtor treatment-based Development Co., Ltd. (hereinafter “Treatment-based Development”) issued a tax invoice with construction services provided to B as a corporation operating a new housing construction and sales business, but the amount of the outstanding construction amount was KRW 14,62,00,000 on the ground that the construction amount was not paid by B.

B. In addition, treatment-based development offered construction services to three-name development companies (hereinafter “sub-name development”), and issued a tax invoice, but the amount of the outstanding construction amount was KRW 10,692,00,000 on the ground that the construction amount was not paid even after three-name development.

C. The treatment-based development considers that the above amount of a bad debt against B and Sejong Construction has become final and conclusive, and applied for the reduction of the amount of a bad debt tax credit pursuant to Article 17-2 of the Value-Added Tax Act on April 16, 2013 to the Defendant for value-added tax 1,332,979,120 won and value-added tax 445,841,860 won for the first period of 2010.

However, on June 17, 2013, the Defendant rendered a disposition rejecting the above corrective claim for the development of treatment-based services on the ground that the requirements for bad debt tax credit were not satisfied (hereinafter “instant disposition”).

E. The development of treatment-based services was dissatisfied with the above disposition and tried by the Tax Tribunal for adjudication, but was dismissed on August 1, 2014.

F. Meanwhile, on August 7, 2014, Daewoodo Development was declared bankrupt by the Seoul Central District Court (2014Hahap132), and the Plaintiff was appointed as a trustee in bankruptcy.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 3, evidence 1 to 2, evidence 3-1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion B was in fact in the first half of 2010, and Sejong Construction was in the first half of 2011, and was in the first half of 201 and was in the absence of assets in his name.

Therefore, the amount of each of the above construction amounts that did not have been developed can be deducted.