2. The Defendant’s corporate tax of KRW 517,817,370 for the business year 2010 owed to the Plaintiff on April 1, 2013.

A. The Plaintiff is a social welfare foundation established under the Social Welfare Services Act, based on the B B large scale 3,664 square meters and its ground buildings, C forest land 384 square meters and D forest land 89 square meters in Sungsung-si as fundamental property.

B. When each land and building belonging to the above fundamental property was expropriated into the Korea Land Corporation on December 22, 2009, the Plaintiff transferred KRW 5,704,313,644 out of gains from transfer to the reserve fund for proper purpose business in the business year of 2009, KRW 1,963,963,823 to the reserve fund for proper purpose business in the business year of 2010, and included in the deductible expenses for the pertinent business year.

C. The Plaintiff acquired each land and building indicated in the relevant table (hereinafter “E building, etc.”) using KRW 6,317,917,827 of the reserve fund for essential business purposes as indicated in the relevant table as shown in attached Table 1.

The Defendant, on April 1, 2013, imposed corporate tax of KRW 1,99,870,370 on the Plaintiff on April 1, 2013 by deeming that the costs incurred in the acquisition of the E-building, etc. were not used for the proper purpose business, and that the said acquisition costs were not used for the proper purpose business, and imposed corporate tax of KRW 6,317,970,370 on the Plaintiff.

E. On May 31, 2013, the Plaintiff dissatisfied with the said disposition and filed an appeal with the Tax Tribunal on May 31, 2013. On June 30, 2014, the Tax Tribunal rendered a decision to partially accept the Plaintiff’s request for a trial to the effect that, since the part (a total floor area of a building 125.92 square meters; hereinafter “instant real estate”) provided for the lease of double-stores, such as E-building, continues to be leased from the time of the Plaintiff’s acquisition of the building, it shall be acquired for profit-making business, and the acquisition cost shall be included in the calculation of the acquisition cost, as the Plaintiff acquired the remainder (hereinafter “F building, etc.”)

F. In accordance with the decision of the above Tax Tribunal, the Defendant shall pay KRW 1,758,401,136 equivalent to the acquisition cost of the instant real estate among the acquisition cost of the building, etc.