1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. Details of the disposition;

A. B, from July 25, 1993, operated a manufacturer of automobile parts under the trade name “C”, and established the Plaintiff on December 30, 201 to convert the business entity into a corporation.

B. The Plaintiff’s capital is a total of KRW 350 million (i.e., KRW 70 million x face value of KRW 50 million x face value of KRW 50 million). The Plaintiff’s statement of change in stocks, etc. (Evidence 2-2) indicated that B invested KRW 1.5 million (per KRW 21,000), KRW 1575 million (per 31,500), and KRW 1575 million (per 17,500) and KRW 875 million (per 17,500).

C. On February 14, 2012, the Plaintiff entered into a contract with B for transfer and takeover of business (Evidence A 6; hereinafter “instant contract”) that comprehensively takes over all rights and obligations regarding the business with B, and the contract is written as follows:

The purpose of this contract is to carry over the transfer income tax under Article 32 of the Restriction of Special Taxation Act and to convert the corporation into the transfer income tax under Article 120 (5) of the same Act by taking over all the rights and obligations of the company under B (C representative) comprehensively by the plaintiff and transferring the business under Article 6 (6) of the Value-Added Tax Act.

Article 2 (Succession to Business) All transaction partners who are in transactions B as of the date of the transfer of business shall accept and guarantee continuous transactions by the plaintiff, and if the products manufactured and sold in B are returned after the date of the transfer of business, they shall be accepted and processed under the responsibility of the plaintiff.

Article 3 (Transferable Assets, Liabilities, and Record Date) The Plaintiff, on December 31, 201, shall take over the total assets and total liabilities on the account books of the same B (C) as of the date of transfer as of December 31, 201, and the assets and liabilities subject to transfer shall be as specified in the attached Form (Omission).

The value of transfer or acquisition by transfer under Article 4 shall be 241,542,024 won, subtracting total liabilities from total assets under Article 3.

except that.