1. On January 2, 2013, the Defendant issued a notice of the change in the amount of income of KRW 4,979,423,00 against the Plaintiff.

1. Details of the disposition;

A. The Plaintiff was a juristic person established on October 1, 1955 and engaged in real estate substitution business, and the Nonparty B, the second shareholder at the time of December 9, 2009, was reduced for value, and thereafter C, the representative director of the Plaintiff, became one shareholder of the Plaintiff.

B. On January 26, 2010, the Plaintiff amended the articles of incorporation to ensure that the articles of incorporation may determine retirement allowances for executives by a resolution of the general meeting of shareholders (Article 35 of the Plaintiff’s articles of incorporation; hereinafter “the provisions of the instant articles of incorporation”); and on September 8, 2010, enacted the retirement benefit payment standard (hereinafter “instant retirement benefit standard”).

C. On December 31, 201, the Plaintiff paid C retirement benefits of KRW 5,043,452,00 in total, and KRW 6,220,434,00 in total, KRW 1,176,971,00 to D (hereinafter “instant retirement benefits”) on the ground that the Plaintiff’s representative director C and D were converted into the annual salary system, and included this in deductible expenses for the business year 201.

The Seoul regional tax office conducted a tax investigation on November 2012 with the Plaintiff on the ground that “the instant retirement benefit standard was made only for a specific executive, and the instant retirement benefit was paid excessively.” Under Article 44(4) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 23589, Feb. 2, 2012; hereinafter “Enforcement Decree of the Corporate Tax Act”) of the instant retirement benefit, the Seoul regional tax office notified the Defendant of the disposition of KRW 4,979,423,00, an amount exceeding KRW 1,241,00,00 corresponding to the “the maximum amount of retirement benefit payment for executive officers other than the case where the amount to be paid as retirement benefit was determined by the articles of incorporation,” and the Defendant notified the Plaintiff of the disposition of KRW 4,035,452,00 and KRW 943,971,00 against D as a bonus to the Plaintiff on January 24, 2013.

(e).