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 established under the Korea Development Bank Act and operated banking business, etc. from March 15, 1954, and raised funds by means of issuance of industrial finance bonds, receipt of deposits and installment savings.

B. When the Plaintiff filed a return of tax base and amount of corporate tax for the business year 2005-2007, the Plaintiff excluded the dividend amount from gross income pursuant to Article 18-3 of the former Corporate Tax Act (amended by Act No. 8831, Dec. 31, 2007; hereinafter the same). The Plaintiff did not include “interest on industrial finance bonds” in the calculation of gross income amount as “interest on loans” deducted from gross income amount.

C. In contrast, the Defendant: (a) deemed that “interest on industrial finance bonds constitutes interest on borrowings as stipulated in Article 18-3(1)3 of the former Corporate Tax Act (hereinafter “instant provision”); and (b) partly revoked the amount of income dividends for the business year from 2005 to 2007 as indicated in the following table; and (c) accordingly, on December 2, 2010, notified the Plaintiff of the correction of corporate tax of KRW 66,431,185,560 (including additional tax) for the business year 2008.

In addition, on November 7, 2011, the defendant found that there was an error in the calculation of the cancellation amount in gross income, and corrected it as shown below.

2,331,871,703 Won 31,319,715,715,845 won for the business year 2005, total of 22,331,871,703 won for the business year 2007, December 2, 2010, 41,225,848,569 Won 94,877,436,117 won for the business year 22,15,671,894 Won 30,224,77 won for the business year 2006, and 39,698,289,02 won for the business year 31,735,185,673 won for the business year 2007.

D. On February 18, 201, the Plaintiff dissatisfied with the disposition of imposition of the above corporate tax and filed an appeal with the Tax Tribunal on February 18, 201. In the decision of the Tax Tribunal rendered on September 4, 2014, the Plaintiff accepted the remainder of the Plaintiff’s assertion, excluding the said portion of the “interest on the industrial finance bonds”, and subsequently, the corporate tax for the business year 2008 was reduced to 25,385,864,956 won

As above, during the initial disposition.