The Plaintiff is a legal entity established on February 26, 1994 for the purpose of real estate sale and lease business, etc., and C was a former director of the Plaintiff until June 11, 2015, since it resigned from the Plaintiff’s representative director on March 31, 2013, and B was a wife of C, who was appointed as the Plaintiff’s representative director on March 31, 2013 and was in that position until February 20, 2017.

C entered into a contract with D on December 17, 2013, under which each of the real estate listed in the separate real estate list (hereinafter referred to as “each of the instant real estate”) was sold in KRW 1,04,90,000,000,000 for the purchase price, and the agreement was entered into between D and D on June 3, 2014, to sell the instant real estate for KRW 1,000,000,000,000.

On July 3, 2014, the Plaintiff completed each registration for the transfer of ownership with respect to forest land of this case, and entered into a contract with D and E to sell the instant 5 real estate of KRW 115,90 million between KRW 429,000,000,000 and KRW 429,000,000,000,000,000,000,000,000,000,000.

On January 2, 2014, the Plaintiff received the down payment of KRW 100 million (which appears to have deposited the down payment that C received to D in accordance with the above sales contract concluded on December 17, 2013 between the Plaintiff and D) from C, and the total sum of KRW 200 million from D, etc. on July 3, 2014, and the remainder of KRW 102,884,088,08, including the remainder of KRW 102,884,08,08 (hereinafter “the instant transfer proceeds”).

The Plaintiff included KRW 402,884,080 in the account book of the instant transfer proceeds in the advance payment for sale, but replaced by the provisional payment on December 31, 2014, but omitted the purchase and sale on the transfer of the instant forest at the time of filing a corporate tax base report for business year 2014.