1. The Defendant’s global income tax amounting to KRW 3,047,457,860 (including additional tax) for the Plaintiff on June 1, 2016.

1. Details of the disposition;

A. The Plaintiff is a person registered as a representative director on the certificate of registration issued by a corporate corporation B (hereinafter “B”) with the purpose of manufacturing and wholesale business of automobile parts. From March 8, 2011 to September 18, 2015, the Plaintiff was registered as the representative director.

B. As a result of the consolidated investigation of corporate tax on B from March 13, 2014 to November 18, 2014, the director of the Central Regional Tax Office of China accounts that the said corporation paid the amount of KRW 6,291,437,500 (hereinafter “instant key amount”) to the KM commerce Co., Ltd. (hereinafter “KM commerce”) as advance payment expenses during the business year 2013, and was investigated as a substitute for the KM trade costs at the time of settlement of accounts, and notified the director of the tax office of emulation of relevant data.

C. On November 1, 2014, the director of the tax office of the U.S. corrected and notified B’s corporate tax for the business year 2013 as non-Inclusion of the instant issues in deductible expenses. On the other hand, the instant issue amount is deemed as a bonus to the Plaintiff, who is the representative director B, on the certificate of registration, but is unclear to the person to whom it reverts, and disposed of it as a bonus to the Plaintiff. On November 3, 2014.

On June 1, 2016, the Defendant decided and notified the Plaintiff of global income tax of KRW 3,047,457,860 (including additional tax).

(hereinafter “instant disposition”) e.

On June 14, 2016, the Plaintiff filed an objection with the director of the Seoul Regional Tax Office, but was dismissed on July 21, 2016. On October 20, 2016, the Plaintiff filed a tax appeal with the Tax Tribunal, but was dismissed on March 27, 2017.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 3, Eul evidence Nos. 1 through 3, 8, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Defendant’s instant disposition of the Plaintiff’s assertion is unlawful for the following reasons, and thus ought to be revoked.

1. The issue amount of this case, which the tax authority considered to have been released from the company, is B.