1. The defendant shall pay to the plaintiff each amount stated in the "payment amount" of attached Form 1 and each of the above amounts.

1. Facts of recognition;

A. The Plaintiff is a key telecommunications business entity under the Telecommunications Business Act, whose purpose is to provide telecommunications services, including the service using radio frequencies, and is designated by the Ministry of Information and Communication as a key telecommunications business entity of IMT-2000, International Mobrocom (hereinafter “instant service”).

B. The Plaintiff paid stamp taxes from December 2009 to December 2010 on the application form for subscription received when providing the instant service to the customer, as indicated in the “paid amount” column in attached Form 1.

C. On August 9, 2012, the Plaintiff filed a request for correction to refund the stamp tax on August 2009 through July 2012, when the application for subscription to the instant service was mistakenly paid, even though it does not correspond to the stamp tax document under the Stamp Tax Act. However, the head of a tax office having jurisdiction over the division refused the refund of stamp tax on September 19, 2012, and the Plaintiff filed a request with the Tax Tribunal for adjudication against the said disposition, but was dismissed on December 30, 2013.

【Ground of recognition】 The fact that there has been no dispute, entry of Gap Nos. 1, 3 through 7 (including each number; hereinafter the same shall apply) and the purport of whole pleadings

2. The parties' assertion

A. In light of the following: (a) the Plaintiff’s alleged mobile phone or personal portable communications and the instant service are different in frequency band, data transmission speed, etc.; (b) the Telecommunications Business Act and the Electronic Telecommunications Act and the Enforcement Decree of the same Act separates the “instant service” from the “ mobile or personal portable communications service” subject to stamp tax documents under the Enforcement Decree of the Stamp Tax Act; and (c) the principle of strict interpretation derived from the no taxation without law, the instant application for service subscription constitutes stamp tax documents stipulated in the Enforcement Decree of the Stamp Tax Act and the Enforcement Decree of the Stamp Tax Act.