1. Of the judgment of the court of first instance, the part against the plaintiff falling under the order to revoke below shall be revoked.

1. Details of the disposition;

A. 1) On August 12, 1999, the Plaintiff accepted 23,514,000 new shares issued by B Co., Ltd. (hereinafter “B”) falling under the specially related party under Article 52(1) of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter “former Corporate Tax Act”) (hereinafter “first subscription price per share: 5,000 won with face value: 5,000 won) (hereinafter “first subscription price”). On April 25, 200, the Plaintiff filed a report on the acquisition of new shares with the Defendant on the tax base of 117,50,505,57 shares issued by the same company as 42,527,885,000 won with face value per share: 5,000 won with face value per share; 200,0000 won with the total of 30,000 won (hereinafter “new shares acquisition price”).

B. On March 27, 2006, the Defendant: (a) on the ground that each of the instant new shares was offered to the Plaintiff for free payment equivalent to the price of each of the above new shares acquired in the form of capital increase issued by the Plaintiff; (b) on the ground that the Plaintiff’s act of acquiring new shares was subject to the denial of wrongful calculation under Article 52(1) of the former Corporate Tax Act, the recognition interest on each of the above new shares acquired amount was included in the calculation of earnings; and (c) on the inclusion of interest paid and the amount of the said securities invested loss in deductible expenses, the Defendant increased and imposed corporate tax

C. On June 16, 2006, the Plaintiff filed an appeal with the Tax Tribunal on the above disposition. On March 24, 2009, the Tax Tribunal filed an appeal on each of the instant new shares acquisition on March 24, 2009, not the grant of funds under Article 88(1)6 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 19328, Feb. 9, 2006; hereinafter “former Enforcement Decree”).