1. Disposition imposing global income tax of KRW 442,646,320 on the Plaintiff on May 1, 2016, and imposing global income tax of KRW 442,646,320 on the Plaintiff.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “B”) is a company for the purpose of selling the Semesters, etc., and is wholly owned by the CCo Corporation, a Japanese corporation, with the aim of owning B’s share.

D Co., Ltd. (hereinafter referred to as “D”) is a company with the purpose of construction business, etc., and the Plaintiff is a person who actually operated D.

B. D entered into a construction contract with B on December 28, 2007, setting the construction cost as KRW 15.9 billion with respect to new construction works of B-style houses.

C. From August 27, 2013 to January 17, 2014, the head of Samsung District Tax Office conducted corporate tax investigation from B’s 2008 business year to 2012 business year (from April 1, 2007 to March 31, 2012). As a result, B’s representative director E, B’s executives and employees F, G, H, and I (hereinafter “E, etc.”) conducted corporate tax investigation in collusion with the Plaintiff, etc., found that part of the construction cost related to the new construction of B was falsely appropriated as processing expenses.

Accordingly, the head of Samsung Tax Office denied the processing cost included in the deductible expenses at the time of filing the corporate tax return during the business year subject to the above tax investigation. On March 3, 2014, the amount found to have been embezzled by E, etc. among the processing expenses with respect to B is the bonus for E, etc., and the amount found to have been reverted to the Plaintiff is the other income of the Plaintiff, and the amount, the ownership of which is unclear, is the other income of the Plaintiff, and notify each change in the amount of income, which is disposed

E. B appealed and filed a request with the Tax Tribunal on March 3, 2014. On March 18, 2015, the Tax Tribunal rendered a decision to revoke the remaining disposal of income except for E’s bonus of KRW 510 million (in 2011), KRW 1.958 million (in 2009, KRW 979 million), other income of the Plaintiff (in 2009, KRW 979 million), and KRW 979 million (in 2010, KRW 2010; hereinafter “the instant income”). On March 27, 2015, the Director of the Tax Tribunal issued a notice of changes in the amount of income pursuant to the purport of the said Tax Tribunal’s decision.