A. On September 27, 2001, in the Incheon District Court 2001. In the case of corporate reorganization, the Incheon District Court 2001. The corporate reorganization company was under the court's management upon the decision of commencing corporate reorganization procedure as of September 27, 2001, the principal and part of reorganization securities and reorganization claims shall be adjusted by conversion of investment through the issuance of new stocks, and the remaining principal shall be adjusted by means of installment repayment, etc., but the above company was decided to authorize the reorganization plan on March 25, 2003 to issue new stocks within the authorized capital stipulated

B. After entering into a merger agreement with the Plaintiff on January 18, 2006, the Incheon District Court issued new shares and permission for capital increase pursuant to the above contract, the Incheon District Court completed the registration of new shares issued in accordance with the capital increase due to the issuance of new shares issued on January 25, 2006 (the face value of KRW 5,000) with the commission of the above court (hereinafter “registration of new shares issued in this case”).

C. Article 128 of the Local Tax Act (amended by Act No. 7972, Sep. 1, 2006; hereinafter “former Local Tax Act”) which was in force at the time of the registration of capital increase with new stocks, provides that “No registration tax shall be imposed on any of the following subparagraphs,” and subparagraph 3 of Article 128 provides that “registration or enrollment by commission of the court on the reorganization of a company or special liquidation”.

On the other hand, the Ministry of Public Administration and Security on December 2, 2004, where registration is made at the commission of the reorganization court with regard to the issuance of new stocks by conversion of loans into equity investment of the reorganization company in accordance with the company reorganization plan under the Company Reorganization Act (amended by Act No. 7428 of March 31, 2005; hereinafter the "former Company Reorganization Act"), the registration tax under Article 128 subparagraph 3 of the Local Tax Act is exempted, but the capital increase registration by capital increase by capital increase by capital increase issued by the reorganization company is not subject to non-taxation of registration tax" as of December 2, 2004.