1. The plaintiff's claim is dismissed.

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

1. Basic facts

A. On December 3, 2012, between the Plaintiff and A (hereinafter “A”) on December 3, 2012, the Plaintiff and the Plaintiff entered into a contract for asset transfer and TC (hereinafter “instant contract”) with a total of KRW 686,459,262, and the total of KRW 264,429,326, and inventory assets of KRW 950,88,588,588, and receives from A the virtual currency equivalent to KRW 97,00,000 (hereinafter “TC”). Meanwhile, the Plaintiff entered into a contract for asset transfer and TC (hereinafter “instant contract”).

B. Under the instant contract, the Plaintiff included the disposal loss of non-performing assets (313,549,368 won, the disposal loss of accounts receivable, 335,719,507 won, and the disposal loss of inventory assets (240,965,802 won) in deductible expenses, which are non-business expenses, and reported and paid corporate tax for the business year 2012.

C. However, as a result of the investigation of A around August 2013, the Defendant: (a) deemed the instant contract as a false contract entered into in collusion with the Plaintiff; (b) denied the loss incurred from the disposal of non-performing assets included in deductible expenses by the Plaintiff; and (c) imposed corporate tax of KRW 24,163,270 for the business year 2012; and (d) imposed corporate tax of KRW 208,636,280 for the business year 2013 on the Plaintiff (hereinafter “instant disposition”).

On October 28, 2014, the Plaintiff requested the Tax Tribunal to decide on the instant disposition, but was dismissed by the Tax Tribunal on June 17, 2015.

[Reasons for Recognition] No dispute exists, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1 and 2 (including paper numbers) and the purport of the whole pleadings.

2. The gist of the Plaintiff’s assertion is that the instant contract in collusion with the Plaintiff and A is not an effective asset transfer contract but an effective asset transfer contract.

3. In light of the following circumstances acknowledged earlier, the Plaintiff’s transfer of assets to A, among the instant contracts, in light of the aforementioned facts, the statement No. 1-2 and No. 3, and the purport of the witness B’s testimony and the entire pleadings.