2. The costs of lawsuit are assessed against the plaintiffs.

A. The plaintiffs prepared a contract for the transfer of 230,00 shares issued (27.83% (27.83%), Plaintiff B 102,00 shares (22.17%), and hereinafter referred to as “the shares of this case”) among the shares issued by C Co., Ltd. (hereinafter referred to as “stock company” in the name of the company”) as of May 25, 2006, and transferred 6,413,780,00 won to C&C as of May 29 (Plaintiff A3,569,408,00 won, Plaintiff B2,84,372,000 won, and transferred 6,40,400,000 won for loans from C&C as of May 29, 2006.

In addition, on July 2006, Plaintiff A reported and paid KRW 290,906,096, and Plaintiff B as capital gains tax, respectively.

B. On May 30, 2006, C opened a board of directors to purchase the instant shares from C&C, and decided that C&C purchase the same amount as the purchase amount from the Plaintiffs, and prepared an existing L&C and its written contract on the same day, and thereafter, C remitted the purchase amount of KRW 6,413,780,000 to C as the amount remitted by the Plaintiffs to C as a loan.

C. After that, C, on March 2, 2009, passed a resolution on the retirement of the instant shares by holding a special general meeting of shareholders, and implemented the retirement of shares, thereby reducing the capital into half.

On March 2, 2009, on which the retirement of the instant shares was implemented, the Suwon Tax Office and the Port Tax Office determined that the constructive dividend income had been occurred to the Plaintiffs on March 2, 2009. On December 2, 2013, the head of the Suwon Tax Office imposed the imposition of global income tax for the year 2009, the head of the Suwon Tax Office imposed on the Plaintiff A the total final tax amount of KRW 1,272,88,310 (including additional tax), and the head of the Suwon Tax Office imposed on the Plaintiff B the total final tax amount of KRW 76,185,970 (including additional tax)

(hereinafter referred to as “instant disposition”). In this case, in the case of the Plaintiff A, 981,982,982, 310 won (including additional tax) calculated by subtracting 290,906,096 won as “paid tax amount” from the total final tax amount of 1,272,88,310 won.