A. Plaintiff A, as the representative director of Plaintiff D (the trade name was changed to E and F Co., Ltd.; hereinafter “D”), held 5,000 shares out of the total number of shares issued D 10,000 shares, and Plaintiff B and C respectively holding 2,50 shares out of the total number of shares issued.

B. On April 21, 2010, the Plaintiffs sold to G Co., Ltd. (hereinafter “G”) KRW 2,100,00 of the Plaintiff’s D Shares KRW 4,000, KRW 2500,000, each of the D Shares 2,500, KRW 2,100,000. On March 30, 2011, Plaintiff A sold the remaining shares of KRW 10,000 to G for KRW 240,000 (hereinafter “instant shares”). The Plaintiffs deemed the shares transfer of a small and medium enterprise as the shares transfer (i.e., KRW 114,30,00, KRW 91,700, KRW 22,630, KRW 200, KRW 201, KRW 507, KRW 2000, KRW 205, KRW 2005, KRW 300, KRW 3000).

C. On April 20, 2010, the Defendant: (a) deemed D’s short-term loans of KRW 500 million (hereinafter “the instant short-term loans”) as provisional payments against Plaintiff A; and (b) deemed D’s provisional payments of KRW 1345 million (hereinafter “the instant provisional payments”) as also against Plaintiff A; and (c) accordingly offset D’s total asset value under Article 94(1)1 and 2 of the Income Tax Act is at least 50/100 of the total asset amount of the relevant corporation; (b) thus, if a shareholder of the instant corporation excessively owned real estate transfers at least 50/100 of the total asset amount of the relevant corporation to a person other than a shareholder, the instant stocks were deemed as the relevant stocks (hereinafter “other assets”); and (c) deemed that the transfer income tax reverted to Plaintiff A for 2010, 2010, 2081, 3081, 2081, 206, 3081, 3081.

(hereinafter referred to as "disposition of this case").