A. On May 23, 1974, the Plaintiff was established by investing 100% of the “HEG Eglesssss CO.Ltdd (hereinafter “HNH”) in the Chinese Honam-Nam of China, as a company that manufactures and produces glass valves for the computer monitors (hereinafter “CRT”), which is a company that manufactures and produces glass valves for the CRT glass, and established by investing 100% of the “HNH” (hereinafter “HGH”).

B. On March 29, 2010, the Plaintiff reported the corporate tax base and tax amount for the business year 2009 to the Defendant with the tax base of 26,789,267,751 won, the total tax amount of 4,859,300,818 won and the total tax amount of 4,859,30,818 won. On December 29, 2010, the Plaintiff claimed that “The Plaintiff’s loans to HNH and the outstanding amount of 79,248,896,922 won (the total amount of 38,822,700,000 operating capital loans of 16,228,289,732 won and other outstanding amounts of 24,197,907,1907,190 won should be added to deductible expenses, and the Plaintiff’s claim for rectification for the business year 205,309,509,209.

C. On February 24, 2011, the Defendant notified the Plaintiff of the dismissal of the claim for corporate tax correction on the ground that it cannot be deemed that HNH discontinued discontinued its business in 2009, and the Plaintiff cannot be deemed as bad debt in the business year 2009 (hereinafter “instant disposition”). D.

On May 11, 2011, the Plaintiff appealed and tried on May 21, 201. On August 21, 201, 201, the Tax Tribunal rendered a reinvestigation ruling that “the actual time of business closure of HNH is 2009, and KRW 16,228,289,732 out of the amount claimed by the Plaintiff did not meet the bad debt requirement, and it is unclear whether the existence of 38,822,70,000 operating loan and other outstanding amounts is 24,197,90,190 won is unclear.” As such, the Tax Tribunal rendered a reinvestigation ruling that “the tax base and tax amount are corrected by examining whether the existence of each claim exists and whether the bad debt requirement is met.”