1. As to January 4, 2016, the Defendant’s imposition of acquisition tax of KRW 1,292,679,690 against the Plaintiff on January 4, 2016, penalty tax for insincere payment is 220.

1. Details of the disposition;

A. On November 25, 2011, and April 23, 2012, the Echeon Ballast Co., Ltd. (hereinafter “Echeon Ballast Co., Ltd.”) concluded a real estate security trust agreement, which constitutes a trust under the Trust Act, with the Plaintiff, with respect to the land of this case, the registration of ownership transfer under the Trust Act was completed on the ground that the said trust agreement was based on the above trust agreement.

B. On August 5, 2013, 201 after completing the registration of a new sports facility business with respect to the said golf course on August 5, 2013, the Leecheon Ballast Co., Ltd. created a golf course with the public knowledge on the part of the instant land, and reported acquisition tax and special rural development tax (hereinafter “acquisition tax, etc.”) to the Defendant following a land category change.

C. As the Leecheon Ballast did not pay acquisition tax, etc. following the change of land category of the instant land, the Defendant served a notice of tax payment, such as the acquisition tax, on November 8, 2013 on the Leecheon Ballast, and served a notice of attachment on January 2, 2014 on the above acquisition tax, etc.

Accordingly, on February 27, 2014, the Echeon Ballast paid all the above acquisition tax, etc.

From October 19, 2015 to October 23, 2015, the Defendant: (a) conducted a tax investigation on the Echeon Ballast; (b) notified the obligor for payment of acquisition tax, etc. following the change of land category of the instant land on January 6, 2016 on the ground that he/she reported and paid the acquisition tax, etc. to the Echeon Ballast, a truster, even though he/she was a trustee; and (c) notified the Plaintiff on January 6, 2016 on the determination of refund, such as return and payment of acquisition tax, etc.; and (d) notified the Plaintiff of the determination of refund, etc. of acquisition tax, etc. based on the change of land category of the instant land category; and (e) notified the Plaintiff of the determination of refund of acquisition tax, etc., by filing a tax return and payment with the Echeon Ballast Ballast, the principal tax of acquisition tax upon the change of land category of the instant land category of KRW 893,598,719,400; and (c) imposition notice on the Plaintiff.

The above disposition of taxation is in this case.