A. On October 27, 2006, the Plaintiff established C Co., Ltd. (hereinafter “C”) in Pyeongtaek-si B to engage in the human resources dispatch business, production contract business, etc., and held office as the representative director.

On May 17, 2010, the Plaintiff reported the closure of business with respect to C at the competent tax office.

B. C did not pay corporate tax for the business year 2010 on March 31, 2011 after filing a return.

C. The head of Pyeongtaek-si Tax Office deemed C’s provisional payment amounting to KRW 504,373,790 on the balance sheet in the business year 2010 as not recovered until the closure of business, and disposed of it as a recognition bonus to the Plaintiff and notified the Defendant of the taxation data.

On November 21, 2012, the Defendant, based on the foregoing taxation data, disposed of KRW 504,373,790 as a provisional payment to the Plaintiff on the basis of the foregoing taxation data, and notified the Plaintiff of the prior notice of taxation amounting to KRW 194,868,468,468 on the premise that the total amount of the Plaintiff’s revenue is KRW 530,373,790.

Accordingly, on December 20, 2012, the plaintiff filed a request for review of the legality of taxation, but the above request was dismissed.

E. On February 7, 2013, the Defendant disposed of the Plaintiff’s provisional payment amounting to KRW 504,373,790 to the Plaintiff, and issued a revised notice of KRW 196,281,155 on the premise that the Plaintiff’s total revenue amount was KRW 530,373,790.

On March 26, 2013, the Plaintiff filed an objection with the Director of Daejeon Regional Tax Office on March 26, 2013, but the said objection was dismissed on April 23, 2013.

F. On July 23, 2013, the Plaintiff filed an appeal with the Director of the Tax Tribunal for adjudication.

On July 15, 2014, the Director of the Tax Tribunal excluded KRW 127,811,913 paid by the Plaintiff to D from the amount of recognized bonuses among the provisional payment amount of KRW 504,373,790 for the Plaintiff on July 15, 2014, and corrected the relevant tax base and tax amount and dismissed the remainder of the Plaintiff’s claims.

G. The Defendant, upon the determination by the Director of the Tax Tribunal on July 24, 2014, reduced the global income tax of KRW 196,281,155 to KRW 54,68,544 by 141,592,61, and 109,404.