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

A. On February 19, 2010, the Plaintiff purchased KRW 50,000,000 per share of C Co., Ltd. (hereinafter “D”)’s non-listed shares of KRW 100,000 per share (hereinafter “instant shares”) from B, a total of KRW 50,000 per share.

At the time, B owned 19,600 shares (49%) among the shares issued by the Plaintiff and constituted a related party under Article 52 (1) of the Corporate Tax Act.

B. On September 28, 2010, the Plaintiff calculated the tax amount based on KRW 2,481,735,930 as the tax base with respect to the corporate tax reverted to year 2010, and reported and paid KRW 80,394,019.

C. As to the transfer of the instant shares to the Plaintiff on February 5, 2013, the Defendant assessed KRW 393,886,000 by deducting the debt amount from KRW 95,150,00 on the asset value on the statement of financial position from KRW 489,036,00, and calculated the market value of the instant shares (=393,886,000/100/100) as the market value of the instant shares). ② The Plaintiff purchased the instant shares from B at KRW 500 per share with the amount of KRW 500 (500 per share) of the former Corporate Tax Act (amended by Act No. 10423, Dec. 20, 2010; hereinafter the same shall apply) by including the difference between KRW 393,86,00,000 from the asset value on the statement of financial position, and calculated the amount of corporate tax for the pertinent business year and KRW 2846,2085,2640.

On July 26, 2013, the Plaintiff sought revocation of the instant disposition to the Tax Tribunal, upon filing an objection on March 5, 2013, but was dismissed on March 18, 2014.

【Ground of Recognition】 Evidence Nos. 1, 2, and 8, and Evidence Nos. 1 and 2