1. Of the instant lawsuits, the part concerning the claim for revocation of the designation of the secondary taxpayer as of November 12, 2012 and March 18, 2013, respectively.

Details of the disposition

A. On December 1, 2008, the Plaintiffs, as married couple, acquired 10,000 shares of C from D (10,000 shares) and E (9,00 shares) as all shareholders of C Co., Ltd. (hereinafter “C”), respectively. From December 2, 2008 to September 27, 2010, Plaintiff A was registered as C director, and Plaintiff B as the representative director of C, respectively.

B. As a result of the investigation of changes in stocks of the Busan Logistics Terminal Co., Ltd. (hereinafter “by-products terminal”), the director of the tax office of the North Busan Busan Busan District Tax Office revealed that C transferred 2,380 shares of the Busan Logistics Terminal Co., Ltd. (hereinafter “the transfer of this case”) at KRW 5,00,000 (hereinafter “the transfer of this case”) owned by C to F who is a lineal ascendant of D and E on November 25, 2008, and notified the Defendant of the disposal of the taxation data by adding 615,54,160 won at a low price to the above shares (2,380 x 2,58,632 won per share) and 5,000,000 won (hereinafter “the transfer of this case”). It stated that C’s 2,380 shares were transferred to F who is a specially related person of this case at a low price, thereby denying the disposal of the taxation data by calculation.

C. On August 1, 2012, the Defendant notified C of the correction of KRW 173,01,330 of the corporate tax (171,521,490, corporate tax attributed to the business year 2008 year) (1,489,840, corporate tax attributed to the business year 2009 year), but C failed to pay it on the grounds of non-property, etc., and on November 12, 2012, C designated the Plaintiffs as the secondary taxpayer on the ground that C was an oligopolistic shareholder. On November 12, 2012, the Defendant notified the Plaintiffs that each share ratio of KRW 91,176,920 (i.e., corporate tax corresponding to 50% of the equity ratio (i., corporate tax belonging to the business year 2008 year 785,120,209, corporate tax belonging to the business year 90,391,800).

Accordingly, on January 25, 2013, the plaintiffs filed an objection, and the director of the Busan Regional Tax Office assessed the value per share of 2,380 shares of the Busan Logistics Terminal that was transferred to F by C on February 21, 2013 to 84,246 won and assessed the value per share of 2,380 shares of the Busan Logistics Terminal as KRW 5 million.