A. The Plaintiff is a corporation established on August 6, 1998 for the purpose of housing construction projects and housing projects. The Plaintiff’s shareholder was from the time of the establishment to the date of its establishment, and E, B, C, and D (hereinafter “E and three others”). From the time of its establishment, E held 40% of the total number of outstanding shares until now, and B, C, and D held 20% of the total number of issued shares, respectively.

E is the representative director of the Plaintiff, B is the Plaintiff’s internal director, and C is the Plaintiff’s auditor.

D is in a relationship with E, and B is an external relationship of E's spouse.

B. The Plaintiff’s offering of new shares was conducted on November 30, 2010, December 16, 2010, and December 28, 2010 on three occasions on December 28, 2010 (hereinafter the following, the Plaintiff’s offering of new shares was referred to as “each case’s offering of new shares”; each case’s offering of new shares is referred to as “each case’s offering of new shares”; and each of the instant offering of new shares is specified as follows.

C.6,000,000 won in total of KRW 16,60,000,00 in KRW 32,200,000 in KRW 32,000 per share on November 30, 2010, KRW 16,000 in KRW 16,000 in KRW 160,00 in KRW 160,000 in KRW 160,000 in KRW 160,000 in KRW 770,000 in December 16, 2010, KRW 28,000 in KRW 28,200,00 in KRW 14,40,00 in KRW C. 14,40,00 in total, KRW 2,200,000 in KRW 24,000 in KRW 14,41,40,000 in KRW 2,200,00 in KRW 214,2812.

C. The Defendant conducted a tax investigation and notified the Plaintiff of the change in the amount of income to the Plaintiff from June 11, 2012 to July 30, 2012, the Defendant conducted a tax investigation with respect to the Plaintiff. The Plaintiff paid KRW 240 million out of the total amount of KRW 1 billion of the subscription price of new stocks E in each of the instant capital increase with consideration for new stocks, and paid KRW 240 million, B, C, and D.