A. On December 11, 2007, E Co., Ltd. (hereinafter “E”) entered into a sales contract with the Gyeonggi-do Local Public Corporation on the purchase price of F 2,439.5 square meters (hereinafter “F land”) at KRW 3,037,177,500, and acquired the ownership of F land. At the time, E’s representative director held KRW 4,000 out of the 10,000 shares of E’s issued stocks, and H owned KRW 3,00 shares, KRW 3,00 shares, and KRW 1,000 shares, respectively (hereinafter “previous shareholders”).

B. On June 20, 2012, K Co., Ltd. (hereinafter “K”) intended to purchase F land from E with a purchase price of KRW 4.5 billion, but the issue of capital gains tax was whether K’s representative director L acquires and develop E’s land by acquiring the stocks of E, and the previous shareholders, L, M, and N drafted a stock transfer agreement (hereinafter “instant stock transfer agreement”) on September 4, 2012, and the main contents related to the instant case are as follows.

§ 1 (Purpose) For the shares of E, the transferor (previous shareholders) and the transferee (L, M and N) shall pay the share transfer price by agreement as follows:

The purchase price: 4,500,000,000 won: The balance of KRW 100,000,000 at the time of the contract for KRW 500,000,000 and KRW 400,000 on September 25, 2012: 4,00,000,000 ( October 25, 2012) shall be transferred to the assignee all rights to share certificates simultaneously with the receipt of any balance.

Article 5 (Cancellation of Contracts) (2) If the transferee delays the due date, he/she shall impose an overdue charge of 14% per annum of the delayed amount.

C. Thereafter, G transferred 4,00 shares, all of which were owned to L, and H transferred 2,00 shares, among 3,000 shares owned, to M, and 1,000 shares, all of which were owned, to M, respectively, and L was appointed as E’s representative director on January 9, 2013.

M is a person who lends a shareholder's name to L, and the shares acquired in M's name are substantially L's shares.

N. With respect to N.