A. From 2003 to 2003, the Plaintiffs jointly operated D Hospital in Gangdong-gu Seoul Metropolitan Government as one-half shares.

In 209 and 2010, the Plaintiffs reported the estimation on the basis of the book-keeping expenses and reported and paid the inorganic penalty tax.

B. From October 24, 2014, the Seoul Regional Tax Office (hereinafter “Investigation Office”) conducted a consolidated investigation of global income tax for the Plaintiffs from October 24, 201 to 2013. During that process, the head of the Seoul Regional Tax Office submitted D Hospital balance sheet, income statement, and total trial balance sheet from the lender accounting firm in 2008 to 2013, and submitted a consolidated investigation of tax evasion under Article 63-11 of the Enforcement Decree of the Framework Act on National Taxes on December 19, 2014, and extended the scope of the tax investigation by the time of global income for the year 209 and 2010.

C. After that, the Defendant received a notice from the Investigation Agency that “the Plaintiff filed an intentional estimate return for the year 2009 and the year 2010, according to the books of account and evidence,” and the Defendant issued a revised notice to the Plaintiff, as of May 12, 2015, of global income tax of 460,076,740 won, and global income tax of 150,417,100 won for the year 2010 as of June 3, 2015, as of May 12, 2015, the Defendant issued a revised notice to the Plaintiff, as of May 12, 2015, of global income tax of 460,179,130 won for the year 209 as of June 3, 2015, and of global income tax of 15,675,200 won for the year 209 as of June 3, 2015.

(hereinafter “each disposition of this case”) D.

The Plaintiffs appealed and filed an appeal with the Tax Tribunal on August 10, 2015, but was dismissed on December 28, 2015.

[Ground of recognition] Facts without dispute, purport of whole pleading

2. Whether each of the dispositions of this case is legitimate

A. The investigating authority on the primary claim of the Plaintiffs’ primary claim does not notify the Plaintiffs of the grounds for extension of the scope of the tax investigation and the scope of the extension, etc. and in fact, the period of investigation is 209.