1. The Defendant imposed corporate tax of KRW 262,59,930 on the Plaintiff for the business year 2008, June 4, 2012, and 223,719.

1. Details of the disposition;

A. The Plaintiff is a corporation established on May 2, 1996 and engaged in the manufacture, sales, etc. of gold-type gold, and mainly manufactures, assembles, and supplies mobile phone parts, which are plastic products, to LG Electronic Co., Ltd. (hereinafter “LG electronic”), and supplies them together from May 2, 2006.

B. In the course of performing the above mobile spool assembly business, the Plaintiff was provided with mobile spool assembly services from Company B (hereinafter “B”), a subcontractor established by the Plaintiff on May 9, 2006, and was provided with gold-type production and repair services necessary for the withdrawal of mobile spool parts from Company D, a personal business chain, the representative director of the Plaintiff (C).

C. From March 8, 2012 to May 16, 2012, the director of the Central Regional Tax Office notified the Defendant of the taxation data stating that “the Plaintiff paid at least 20% of the assembly unit price designated by LG electronics (hereinafter “LG electronic designation unit price”) and paid the gold repair cost arbitrarily to D,” after conducting a tax investigation with the Plaintiff.

Therefore, by applying the provision of the rejection of unfair act under the Corporate Tax Act, the Defendant: (a) excluded the Plaintiff’s payment in excess of the designated rate of LG electronic designation from deductible expenses; and (b) rendered a decision to reduce the Plaintiff’s deficit of KRW 780,630 for the business year 2007, by 352,536,60, corporate tax for the business year 2007, corporate tax of KRW 340,428,480, and corporate tax of KRW 396,58,570 for the business year 2009; and (b) made a decision to reduce the Plaintiff’s deficit of KRW 1,344,748,00 for the business year 2010, KRW 780,630,00 for the business year.

E. Accordingly, it is unreasonable that the Tax Tribunal excluded the entire amount of the gold repair cost paid to D as of December 17, 2012 from deductible expenses in the tax appeal filed by the Plaintiff on July 3, 2012. As such, the Plaintiff is from D.