2. The costs of lawsuit shall be borne by the Plaintiff.

From January 1, 2012 to December 31, 2016, the Plaintiff paid KRW 475,00,000 ( KRW 95,00,000 x 5) each year in the name of salary to B (the Vice-Chairperson of the son) who is a full-time director of the Plaintiff (the Vice-Chairperson of the son C) as a juristic person engaged in manufacturing and wholesale and retail business of dental equipment, and set KRW 20,92,799 as the allowance for severance benefits (hereinafter “the instant salary, etc.”).

The Plaintiff traded with D Co., Ltd. (hereinafter “Co., Ltd.”) (hereinafter “Co., Ltd.”), E, F, G, and H (hereinafter collectively referred to as “instant transaction partner”). From 2013 to 2015, the Plaintiff delayed collection of sales claims for more than three to six months from the 15th day of the following month, which is the ordinary payment date, from 2013 to 2015 (hereinafter “instant delayed collection of sales claims”).

(H) In the year 2014, 2015, the Plaintiff actively paid advance payment to the said business entity. The Seoul Regional Tax Office conducted a tax investigation (hereinafter “instant investigation”) with respect to the Plaintiff from July 11, 2017 to September 22, 2017, deeming that B had not actually worked for the Plaintiff, and subsequently denied the instant benefits, etc. and excluded the Plaintiff from deductible expenses by wrongful calculation, and at the same time notified the Defendant of the outcome of investigation by deeming that (i) the Plaintiff delayed the collection of sales claims from the instant transaction parties without justifiable grounds; (ii) deeming that the Plaintiff delayed the collection of sales claims from the instant transaction parties; (iii) applying the provision of the provisional payment without due cause, the said interest shall be included in deductible expenses by applying the provision of the unfair calculation registry; and (iv) deeming that the amount equivalent to entertainment expenses, such as surgery ki, which the Plaintiff supplied without compensation, constitutes entertainment expenses.

On November 1, 2017, the Defendant issued a notice of imposition and notification of each corporate tax for each of the business years from 2012 to 2016 (hereinafter “the initial disposition”).