1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The plaintiff is separated from C Co., Ltd. for the purpose of selling communications equipment, and the plaintiff is a company incorporated on May 14, 2007, and B is serving as the representative director.

B. On February 23, 2012, the Plaintiff purchased 20,400 shares of the Plaintiff Corporation from C Co., Ltd. for KRW 10,00 per share, and on February 24, 2012, sold the said shares to B at KRW 10,00 per share.

(hereinafter) On March 20, 2012, B sold 6,600 shares out of the above shares to D, E, F, G, H, and I, an employee of the Plaintiff, KRW 10,00 per share.

In addition, on December 21, 2012, the Plaintiff purchased 4,200 shares of the Plaintiff Corporation from J for KRW 10,00 per share.

(hereinafter referred to as “second transaction” and “second transactional shares” (hereinafter referred to as “second transactional shares”).

The director of the Seoul Regional Tax Office conducted a tax investigation on stock change with the Plaintiff from October 20, 2014 to December 17, 2014, and reported the first transaction as low-price transfer, second transaction as low-price purchase, and third transaction to the director of the Seoul Southern-gu Tax Office on March 5, 2015.

Accordingly, on March 5, 2015, the director of the Seoul Southern District Tax Office imposed corporate tax of 369,084,720 won on the Plaintiff for the business year 2012. The director of the Seoul District Tax Office notified the Plaintiff of the change in income amount (income amount of 2012, income amount of 1,249,867,200, income amount of 1,249,867,200, income amount of 200) on the same day. In relation to the second transaction, the director of the Seoul Southern District Tax Office imposed corporate tax of 2013,3190 won on the Plaintiff on the same day.

(hereinafter collectively referred to as "disposition of this case"). (e)

On May 7, 2015, the Plaintiff filed an appeal with the Tax Tribunal on May 7, 2015, but was dismissed on September 9, 2015.

[Ground of recognition] A without dispute, Gap evidence Nos. 1 through 9, Eul evidence Nos. 1 and 2 (including paper numbers), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1 is from C Co., Ltd or J.