A. On June 7, 2006, the Plaintiff concluded a contract with B Co., Ltd. (hereinafter “instant share transfer contract”) to transfer the instant shares to C on June 7, 2006 (hereinafter “instant share transfer contract”) by holding 25,188 shares of B Co., Ltd. (hereinafter “Nonindicted Corporation”) (hereinafter “instant shares”) and transferred all of the instant shares to C on August 1, 2006 by receiving the down payment of 1.5 billion won on the same day, and receiving the balance of 9 billion won on August 1, 2006.

B. On September 11, 2006, the Plaintiff reported capital gains tax of KRW 52,50,000 on September 11, 2006, and KRW 2,216,096,110 on October 30, 2006, and paid in full within the payment period.

C. On August 1, 2006, the Defendant imposed corporate tax of 4,05,854,370 won (this case’s corporate tax of 2006,392,41,823 won, additional tax of 1,613,42,539 won, hereinafter “the corporate tax of this case”) on September 1, 2010, based on the circumstance that the building of 164.6m2 and 164m2 and 3m2 on the land of this case’s land, which is the only asset of the non-party corporation, was transferred to the non-party corporation C, on August 1, 2006, which is the remainder payment date of the stocks of this case.

As the Defendant did not pay the above corporate tax, on December 31, 2006, deemed the Plaintiff as an oligopolistic shareholder who owned 100% of the shares issued by the said corporation as of December 31, 2006, and notified the Plaintiff to designate the Plaintiff as the secondary taxpayer of the corporate tax of this case pursuant to Article 39(1)2 of the Framework Act on National Taxes (amended by Act No. 8139, Dec. 30, 2006; hereinafter the same) and pay KRW 4,005,854,370 of the corporate tax of this case as of November 9, 2010.

(hereinafter referred to as the “instant disposition of imposition”). E.

On the other hand, the defendant was the representative of the non-party corporation with the amount of 10 billion won included in gross income.