A. On March 31, 2009, the Plaintiff returned corporate tax on March 31, 2009 to the Defendant for the business year of 2008, and reported corporate tax by including the amount equivalent to the deposit repayment obligation for which five years have passed since the last transaction date, which was five years after the expiration of the commercial extinctive prescription period, from among the deposit repayment obligation arising from the deposit transaction between the Plaintiff and the Plaintiff’s customer, in the gross income (hereinafter “instant money”).

B. On December 2, 2011, the Plaintiff filed a request for correction of reduction to the effect that the Defendant would refund KRW 5,608,833,230 of the corporate tax reverted to the business year 2008 on the ground that the inclusion of the instant money in gross income was erroneous, etc., but the Defendant rejected the Plaintiff’s request for correction of reduction on February 6, 2014.

C. On May 9, 2014, the Plaintiff appealed and filed a petition with the Tax Tribunal for an adjudication on the instant disposition, but the Tax Tribunal rendered a decision to dismiss the Plaintiff’s petition on December 17, 2014.

On the other hand, on August 23, 2016, when the lawsuit of this case is pending, the Defendant corrected ex officio the Plaintiff’s 1,631,132,471 of the corporate tax belonging to the business year 2008 by reducing the amount of KRW 1,631,132,471 of the Plaintiff’s corporate tax. (hereinafter “the Defendant’s disposition rejecting the remainder of the disposition rejecting the Defendant’

(2) Of the instant money, the Plaintiff’s payment of interest during the extinctive prescription period to the customer is excluded from the gross income, and the amount of KRW 12,488,974,851, which was confirmed to have been interrupted, reflects the result of tax adjustment and the Plaintiff’s reduction of corporate tax for the business year 2007, thereby affecting the subsequent business year.