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

A. The Plaintiff, a corporation engaged in the manufacture, repair, etc. of rolling stock, filed a report on the amount of income for the business year 201 with the Defendant as KRW 8,364,724,727, the tax base of KRW 239,046,683, and the amount of income for the business year 2012 as KRW 7,196,216,469, and the tax base of KRW 180,825,483.

B. From March 7, 2016 to March 26, 2016, the Defendant conducted an integrated investigation into the Plaintiff with respect to the Plaintiff. On March 25, 2016, the Defendant demanded the Plaintiff to submit explanatory materials as to the aggregate of the cost of external processing against B (C, D), E (F, G, H), I (J, K, and L (hereinafter collectively referred to as “B, etc.”) alleged to the Plaintiff as a party to the transaction of external processing costs.

C. Upon completion of the above tax investigation, the Defendant: (a) included only KRW 516,860,00, which was verified as actual payment, among KRW 1,376,547,818 included in the cost of external processing at the time of filing a corporate tax return for the business year 201; and (b) included the difference of KRW 859,687,818 in deductible expenses for which the determination as to whether to pay was confirmed, and disposed of as bonus for the representative.

In addition, the defendant confirmed that the plaintiff's 641,572,00 won, which was claimed by the plaintiff among the 641,572,00 won included in the cost of external processing in the cost of daily work for M and N at the time of filing a corporate tax for the business year 2012, the amount of KRW 530,032,00 that the plaintiff claimed that he paid to O, P and Q as bonus each of the above 10,000 won, was false, and 560,032,000 won, which is the aggregate of the above amounts, was excluded from deductible expenses, and disposed of other income for each of the persons to whom it belongs or its representative.

E. According to the result of the above tax investigation, on June 1, 2016, the Defendant notified the Plaintiff of each correction of KRW 343,573,090 of the corporate tax for the business year 201 (including additional tax of KRW 154,441,77) and KRW 187,05,980 of the corporate tax for the business year 2012 (including additional tax of KRW 76,957,040).

(f) Each disposition of this case (hereinafter “each of the instant dispositions”). The Plaintiff each of the instant dispositions.