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

A. As the Plaintiff did not pay KRW 95,197,140 in total amount of eight national taxes, the Defendant deemed that the Plaintiff fell under the oligopolistic shareholder B (57.12%) as of the date on which the liability for tax payment was established, and on March 9, 2018, the Plaintiff designated the Plaintiff as the secondary taxpayer and notified the Plaintiff of payment for KRW 54,376,520, including corporate tax, as follows:

(B) The tax amount of wage and salary income of the second taxpayer (Plaintiff) on September 30, 2016; 57.12% on June 30, 2016; 3,701,390 corporate tax on October 31, 2016; 17,245, 980 corporate tax on August 31, 31, 2016; 30.6.6.31, 208; 30.6.6.8, 207.8; 4.6.8, 207.8; 3.6.8,80, 80; 16.35.4; 1.6.4.4; 1.6.35.4; 205.6.3.6.4. 20, 2016; 3.4.5.31.31.37, 37, 2017;

B. On April 6, 2018, the Plaintiff filed a request for examination to the Commissioner of the National Tax Service against this request, but a ruling dismissing the Plaintiff’s request was rendered on June 5, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 (including paper numbers), Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion (1) in preparation for the occurrence of a conditional investment agreement, the Plaintiff acquired B shares 20,000 shares with bonds as collateral (hereinafter “instant shares”) and did not pay the actual share price.

Furthermore, since the above conditional investment agreement has been withdrawn by agreement between the parties, the acquisition of the shares of this case has become null and void, and the plaintiff has no right as a shareholder of B.

Therefore, the instant disposition taken on the premise that the Plaintiff is a shareholder is unlawful.

(2) Even if the content of the investment agreement that was changed to February 13, 2016, the Plaintiff’s share in B is considered.