1. On August 1, 2016 and October 4, 2016, the Defendant issued an increase or decrease of value-added tax for the second period of two years against the Plaintiff on August 1, 2016 and on October 4, 2016.

1. Details of the disposition;

A. On January 7, 2015, the Plaintiff was decided to commence rehabilitation procedures as Seoul Central District Court 2014 Ma100212, and was decided to obtain the rehabilitation plan approval on July 3, 2015.

(hereinafter referred to as the “instant rehabilitation plan”). B.

The instant rehabilitation plan provides that “(i) for rehabilitation creditors with a special relationship, the principal and interest shall be converted into 85%, and 15% shall be paid in cash, ② for other rehabilitation creditors, 50% of the principal and interest before commencement shall be paid in cash, and 50% shall be paid in cash, and the obligations to be converted into equity shall be substituted for the repayment of the relevant rehabilitation claim on the effective date of the shares newly issued by the debtor. The common share and the first share shall be converted into 5,000 won with the face value of 5,000 won and the first share shall be converted into 1 share, respectively. However, the entire shares converted into equity for the obligations of a person with a special relationship with a rehabilitation claim shall be retired without compensation.”

C. According to the instant rehabilitation plan, the remaining amount of the rehabilitation claim against the Plaintiff was converted into equity, and shares acquired by B, C, D, and E (hereinafter collectively referred to as “specially related parties”) among new shares issued through a conversion into equity, which are rehabilitation creditors having a special relationship with the Plaintiff, were all retired without compensation. Shares acquired by F, G, H, H, I, J, J, and K (hereinafter collectively referred to as “non-specially related parties”), which are rehabilitation creditors who do not have a special relationship with the Plaintiff, were consolidated at the ratio of 5:1 on July 31, 2015.

A person with a special relationship and a non-specially related person (hereinafter collectively referred to as "the rehabilitation creditors of this case") shall be the difference between the book value of rehabilitation claims subject to conversion of investment and the market value of the stocks delivered through conversion of investment according to the rehabilitation plan of this case.