2. The costs of lawsuit are assessed against the plaintiffs.

A. C Co., Ltd. (hereinafter “C”) is a corporation that provides consultation, development, supply, and maintenance services of software, and sells computers and peripheral devices.

A Co., Ltd. (hereinafter referred to as “Plaintiff Co., Ltd.”) is a corporation that is engaged in the business of developing and consulting system integration programs, and B (hereinafter referred to as “Plaintiff”) is the largest shareholder and the representative director of the Plaintiff Co., Ltd. (hereinafter referred to as “Plaintiff Co., Ltd.”).

B. The Plaintiffs participated in the increase of C’s capital on March 30, 201, and acquired each of the shares of 60,000 shares (33.3%) and 40,000 shares (22.2%) of the Plaintiff (hereinafter referred to as “instant shares”) by the Plaintiff Company.

C. On June 24, 2014, the Defendant: (a) determined and notified the Plaintiffs as the oligopolistic shareholder C’s oligopolistic shareholder of KRW 70,617,410, and KRW 10,017,650, and KRW 83,003,200, total amount of KRW 2,370,960, and KRW 2,370,960, which are withheld for the year 2013; (b) the value-added tax for the second period of 2012, which is in arrears by C; and (c) the wage and salary income tax for each year of 2013, 2014, as well as retirement income tax for the year 2013.

(hereinafter referred to as “instant disposition”). [Grounds for recognition] An absence of dispute, Gap’s 1 through 7, 10 evidence (including branch numbers; hereinafter the same shall apply), Eul’s 1 and 2 evidence, and the purport of the whole pleadings.

2. To make entries in the attached statutes concerned;

3. Whether the instant disposition is lawful

A. Article 39 of the former Framework Act on National Taxes (amended by Act No. 12848, Dec. 23, 2014; hereinafter “the Act”) provides that “any of the following persons shall be subject to secondary tax liability.” In subparagraph 2, a shareholder or one limited partner and his/her related party, as prescribed by Presidential Decree, and the total amount of stocks owned or invested by the shareholder or one limited partner and his/her related party.