A. The Plaintiff subrogated at around 2002 the amount of KRW 27,405,96,301 (hereinafter “becker”) which was established in the territory of the Republic of Korea on the part of the Republic of Korea for the purpose of entering the hotel development project on behalf of the Plaintiff for the loan debt of KRW 27,405,96,301 (hereinafter “becer”) from the financial institution under the Plaintiff’s guarantee on behalf of the Plaintiff, and on reporting the tax base and tax amount of the corporate tax for the business year of 2002 to the Defendant, the Plaintiff calculated the estimated amount of KRW 8,204,743,00,00, and deducted it from its deductible expenses at KRW 19,201,201,261,307,409,300 (hereinafter “becercer’s loan claim”).

B. From November 15, 2006 to April 23, 2007, the Seoul regional tax office conducted the Plaintiff’s consolidated investigation of corporate tax for the business year 2002 to 2005. On May 8, 2007, the Defendant: ① The Defendant included the Plaintiff’s bad debt amount of 19,201,261,261,301 in deductible expenses as bad debt for the business year 2002, out of the claim for indemnity against the Plaintiff’s overseas subsidiaries, in deductible expenses for the business year 19,201,261,261,301 in deductible expenses as of December 26, 2008 (amended by Act No. 9267, Dec. 26, 2008; hereinafter “former Corporate Tax Act”) in deductible expenses; ② the amount of bad debt of this case is substantially the same as the above amount leased to be paid without compensation; ③ The Defendant shall be deemed to have no special relationship with the Plaintiff’s business year 3050, 20139,205.75.