A. The Plaintiff is the American College Ability Test (Scast Aptude, SAT) located in Gangnam-gu Seoul Metropolitan Government D.

B. From August 31, 201 to October 10, 2011, the director of the Seoul Regional Tax Office: (a) conducted a corporate tax investigation for the business year of 2008 to 2010 with respect to the Plaintiff, Non-Party E Co., Ltd. (hereinafter “E”) and Non-Party F Co., Ltd. (hereinafter “F”), which is the Plaintiff’s related company; (b) deemed that there is a difference between the amount of tuition fees and the reported amount under the ACA Program (ACA) used by the Plaintiff; and (c) determined that there is a difference between the amount of tuition fees and the reported amount; and (d) notified the Plaintiff on October 18, 201 as a result of the tax investigation conducted prior to the imposition of corporate tax of KRW 4,372,370 and corporate tax of KRW 71,466,300 in the year 209.

C. On November 22, 2011, the Plaintiff dissatisfied with this, filed a request for pre-assessment review with the director of the Seoul Regional Tax Office, and the director of the Seoul Regional Tax Office rendered a decision of re-assessment in the pre-assessment review on January 13, 2012. Accordingly, the director of the Seoul Regional Tax Office conducted a re-audit against the Plaintiff from February 1, 201 to April 16, 2012. As a result, the director of the Seoul Regional Tax Office notified the head of the Seoul Regional Tax Office of the imposition of the disposition accordingly.

According to the above notification, on June 11, 2012, the chief of the Defendant Samsung District Tax Office imposed corporate tax of KRW 4,54,760 in 208, corporate tax of KRW 58,854,920 in 209 (hereinafter “instant disposition”), KRW 28,545,00 in 208, KRW 18,670 in 2010, and KRW 18,670 in 2010 in 2010, and KRW 57,90 in 209 in 2010 on the representative director B, and KRW 57,900 in 209 in 2010, respectively.