A. Plaintiff C and D are the parents of Plaintiff A and B as the husband and wife, and the Defendant is a tax accounting corporation that from around 2008, the Plaintiff and D owned all outstanding shares (50,000 shares) at the request of the F Co., Ltd. (unlisted corporation; hereinafter “F”).

B. (1) On March 2018, the Defendant responded to Plaintiff C’s inquiry about the issue of donating the shares held by Plaintiff C and D (hereinafter “instant shares”) to Plaintiff A and B on the basis of the F’s financial statements, etc. prepared as of December 31, 2017, and then, “if the instant shares held by Plaintiff C and D are donated to Plaintiff A and B, the amount of taxes worth KRW 120 million should be imposed.” On the Plaintiff’s inquiry about the resolution of the shortage of the payment of gift tax and capital reduction of capital, the amount of gift tax may be less than KRW 120,000 should be refunded through reduction of capital, and the amount of capital necessary for reduction of capital may be provided with a bank loan to KRW 50,000,000.” On April of the same year.

(2) On May 25, 2018, the Plaintiffs determined that if the Defendant pays the expected amount of tax in trust, they may donate and increase the shares of this case to the Defendant. On May 25, 2018, the Plaintiffs entered into a service contract (the “instant service contract”) with the Defendant, under the name of the Plaintiff C, with the content that the Defendant would be able to provide services related to the tax affairs, such as the assessment of shares following the donation of the shares to Plaintiff C and D to Plaintiff A and B, the adjustment of shares due to the reduction of F capital, and the report of the amount of gift tax due to the donation of shares, and the Plaintiff C shall pay five million won in remuneration to the Defendant.

(3) After June 15, 2018, F.I.D.