1. In order for a contract to be concluded, the agreement between the parties is required to be reached, and such agreement is not required with respect to all matters constituting the content of the contract in question, but with respect to the essential or important matters, there must be an agreement with the specific intent or at least an agreement on standards and methods that can specify the future in detail. In the event that no agreement or agreement is reached, it is reasonable to deem that the contract was not concluded, barring any special circumstances.

(See Supreme Court Decision 200Da51650 Decided March 23, 2001, and Supreme Court Decision 2011Da102080 Decided June 28, 2012). Moreover, an offer, which is a legal requirement for the formation of a contract, must be specific and conclusive that the contract is concluded immediately if the offer accepts the offer. As such, it is necessary to include matters to the extent that the content of the contract can be determined.

(See Supreme Court Decision 2001Da53059 Decided April 11, 2003, and Supreme Court Decision 2003Da41463 Decided December 8, 2005). 2. According to the reasoning of the lower judgment and the record, the following facts are revealed.

The F Co., Ltd. (hereinafter “F”) purchased gold at home from February 9, 2009 to June 201, 201, and exported gold bullion in the form of Alleybrid to Hong Kong.

With respect to F’s gold export business, the Plaintiff invested a total of KRW 740 million from February 5, 2009 to March 16, 2009 to F.

B. On September 6, 2010, the head of Sung-dong Tax Office deemed that F filed a corporate tax return by appropriating the excessive purchase price of gold in the business year of 2009, imposed a disposition imposing KRW 3,826,95,790 on F for the business year of 2009.

F is the Seoul Administrative Court 2012Guhap2287 to seek revocation of the disposition of the above corporate tax, etc.