1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance, such as accepting the judgment of the court of first instance, is as stated in the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as stated in the following (3). As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

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3. Supplementary and additional Plaintiff asserts as follows.

① Each of the instant transaction partners entered into a contract for transportation with the Plaintiff, and actually supplied transportation services to the Plaintiff using each of the instant vehicles owned by the Plaintiff.

Therefore, the instant tax invoice is not a false tax invoice.

② Since each of the transaction parties of this case has already paid value-added tax corresponding to the tax invoice of this case, it is illegal to impose value-added tax on the plaintiff for the same transportation service as double taxation.

③ Even if the actual business operator is the Plaintiff, the actual business operator should impose only the remaining tax amount after deducting the value-added tax already paid by each of the transaction parties of the instant case according to the general rules of the Framework Act on National Taxes and the precedent of preliminary determination.

④ The actual supplier of the instant service is not a tax invoice different from the facts, but the instant tax invoice was actually supplied to the Plaintiff by each of the instant transaction parties. As such, the instant tax invoice was not subject to penalty, since each of the instant transaction parties was actually supplied to the Plaintiff.

As stated in the judgment of the first instance court cited by this court, the process of the use of name, the degree and scope of involvement of each of the transaction parties of this case, and internal responsibilities and accounting relations shall be comprehensively considered.