1. The Plaintiff’s respective lawsuits against Defendant B, Defendant D, and Defendant E are dismissed.

2. The prosecution against Defendant C is serious.

1. Basic facts

A. The Plaintiff (F) is a company established for the purpose of export and import business, export and import agent business, etc. The network G is the mother of H, I, and the Defendants, the Plaintiff’s major shareholder. 2) On April 27, 2007, the Defendants transferred the Plaintiff’s shares (hereinafter “instant shares”) to the Plaintiff (hereinafter “instant shares transfer”) as indicated below (hereinafter “instant shares transfer”), and reported and paid each transfer income tax on June 30, 2007.

The name-based shares of 1 B 49,810 16,500 821,865,000 2 C 49,810 16,500 821,865,865,000 3D 69,574 16,500 16,147,971,000 4 E 219,016,503,613,613,764,000 total 388,210 6,405,465,000

B. After the collection disposition of dividend income tax and administrative litigation related thereto, the head of the Suwon Tax Office returned and paid transfer income tax by the Defendants on the ground that the gains from transfer acquired by the Defendants constituted deemed deemed deemed deemed dividend through the transfer of the instant stocks. On May 8, 2012, the Plaintiff asserted that the disposition of collecting the principal tax for the dividend income tax for the year 2007 and the disposition of imposing and collecting the additional tax of KRW 77,960,026 is the disposition of imposing and collecting the said tax. However, Articles 21(2)1 and 22(2)3 of the former Framework Act on National Taxes (amended by Act No. 8830, Dec. 31, 2007; hereinafter the same shall apply) are the disposition of imposing and collecting the said tax.

According to Articles 17(1) and 127(1)2, dividend income tax is income tax withheld at source, and is automatically determined at the same time as the tax liability is established at the time of payment of income or revenue amount.

Therefore, if the Plaintiff, a withholding agent of dividend income tax, did not pay the dividend income tax, and the Defendant issued a tax payment notice to the Plaintiff by adding additional tax to the principal tax amount of dividend income tax.