2. The costs of lawsuit shall be borne by the Plaintiff.

A. Defendant B accounting corporation (hereinafter “Defendant corporation”) is an accounting corporation in charge of the Plaintiff’s tax return agency from 2005 to 2010, and Defendant C was a certified public accountant affiliated with the Defendant corporation in charge of the Plaintiff’s accounting service at the time.

B. On January 7, 2008, the Plaintiff entered into a contract with D to sell all the Plaintiff’s shares and all the equipment, such as dredging vessels owned by the Plaintiff for KRW 1,450,000,000,000. When D paid KRW 700,000,000, the remaining contractual obligations were not fulfilled. As D’s shares owned by the Plaintiff E and F were transferred to D.

After that, E and F have withdrawn some of the above KRW 700 million and used them to redeem their liabilities.

C. Defendant C appropriated KRW 700,000,000 deposited into the Plaintiff’s account as the advance payment on the account book, and then, on January 1, 2009, this was offset against KRW 700,000 for the representative director.

Based on the reasoning that the above advance payment and the provisional payment are different from the creditor and debtor, even if the plaintiff were to be different, the representative director omitted the interest rate on the provisional payment and omitted the tax adjustment of the interest paid in relation to the provisional payment unrelated to business affairs, the Changwon did not include the amount of 59,50,000 won equivalent to the interest paid in 209 and 2010, and did not include the interest paid in 68,92,000 won paid in 2010, and did not include the amount of 68,992,000 won paid in deductible expenses in March 10, 2012, and notified the corporate tax of 1,228,130 won in corporate tax of 209 and corporate tax of 30,822,610 in 2010.

Accordingly, the Plaintiff paid the above notification amount on October 7, 2013.

E. As to this, the Plaintiff filed a lawsuit seeking revocation of the disposition imposing corporate tax after filing an objection against the Director of the Changwon Tax Office, the Commissioner of the National Tax Service, or a request for review, but the judgment was rendered final

(J) The fact that there is no dispute over the Changwon District Court 2013Guhap930, Busan High Court 2013Nu10185, Supreme Court 2015Du45588).