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A. B Co., Ltd. (hereinafter “instant corporation”) is a corporation for the purpose of lodging and restaurant business, sports facility business, resort condominium business, etc., and the period of service as the representative director of the instant corporation at the time of 2012 on the entire certificate of registration of the corporation is as listed below.

During the term of office of the representative director, Plaintiff 4 from January 4, 2012 to May 13, 2013: C from September 19, 2011 to January 4, 2012; or D from March 5, 2011 to November 5, 2012 from March 30, 2012 to November 1, 2012 E from August 30, 2012 to September 30, 2012 to September 28, 2012. < Amended by Act No. 11401, Dec. 5, 2013>

The Seoul Regional Tax Office conducted an integrated investigation of corporate tax for four business years from July 1, 2009 to June 30, 2013 of the instant corporation, and confirmed that the said corporation failed to report corporate tax for two business years from July 1, 2011 to June 30, 2013, and estimated the amount of income of the said corporation for the pertinent business year, assessed the amount of income of the said corporation for each business year, disposed of the bonus by dividing it by the period of service to the representatives of the said corporations, and notified the Defendant of the taxation data.

C. The Defendant notified the Plaintiff of the change in income amount of KRW 57,59,561 in the bonus disposal amount for the first half of the year 2012, and KRW 656,619,975 in the second half of the year 2012, totaling KRW 99,060,414 in the second half of the year 2012, and decided and notified the Plaintiff on May 3, 2016, global income tax of KRW 331,990,820 in the amount of the above recognized bonus amount for the year 2012 (including additional tax).

(hereinafter “instant disposition”) D.

On July 25, 2016, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal. On December 1, 2016, the Tax Tribunal rendered a decision that “The Plaintiff should re-examine whether the Plaintiff was the actual representative of the instant corporation, and revise the tax base and tax amount according to the result.”

E. The director of the Seoul Regional Tax Office conducted a reinvestigation on the instant disposition in accordance with the aforementioned decision of the Tax Tribunal, but the result of reinvestigation that the initial disposition is deemed justifiable and maintained as is, is the Plaintiff on January 24, 2017.