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

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

2. Whether the instant disposition is lawful

A. The Plaintiff’s primary assertion 1) The price for the transfer of the instant shares is calculated on the basis of KRW 18,000 per share to be paid from KRF pursuant to the instant secondary sales contract. The Plaintiff agreed to receive the amount of credit exceeding the sales price of the instant shares out of the exercising price for the option of sale from the gold industry (hereinafter the corresponding Plaintiff’s claim against the gold industry is referred to as “instant workout claim”).

(2) The Plaintiff asserts that the tax base of securities transaction tax on the transfer of the instant shares should be KRW 18,00 per share since the difference arising from the exercise of the claim for joint sale under an agreement between the shareholders under a separate special agreement from the instant secondary sales contract is to be compensated for, or the principal and interest on loans to the compensation agreement or gold industry arising from the nonperformance of the instant first sales contract is to be returned, and is not irrelevant to the transfer of the instant shares. Thus, the Plaintiff asserted that the tax base of securities transaction tax on the transfer of the instant shares should be KRW 18,00 per share. 2) Even if the instant workout claim is included in the transfer price of the instant shares, the instant workout claim was agreed to comply with the plan for debt readjustment stipulated in the plan for the normalization of the management of the gold Industry from the beginning. However, the Financial Council of creditor Council agreed to compensate for the amount of 14,626 won per share among the instant bonds to be redeemed at least 14,626 won per share (12,287 won per share) and the remainder of the stock transfer of shares.