1. The Defendant’s corporate tax of 73,260,920 won for the business year of 2007 against the Plaintiff on October 2, 2012, and corporate tax for the business year of 2008.

1. Details of the disposition;

A. The Plaintiff, a corporation that manufactures and sells vessel equipment, such as a remote valve control system for vessels, to a shipbuilding company, supplied a product to a shipbuilding company on condition of approval for the shipowner, paid to the shipowner the amount at a certain ratio of the supply price (hereinafter “market price”), and then reported corporate tax by appropriating the price at the expense in the payment fee account.

B. The director of Busan Regional Tax Office conducted a consolidated investigation of corporate tax against the Plaintiff, and deemed that the amount at issue constitutes entertainment expenses, and notified the Defendant of the amount exceeding the limit of entertainment expenses not to deductible expenses and imposing corporate tax on the Plaintiff. Accordingly, on October 2, 2012, the Defendant imposed KRW 582,122,860 on the Plaintiff as listed below for the business year from 2007 to 2011.

(hereinafter referred to as the "disposition of this case"). (The unit: 340,475,5,590 589,357,062 741,95,218,218,45,360,347,447, 447, 757,57,594,675,575,592,59775,59775,59775,52,5162,459,701,29,27129,294,7165,7207,7205,5075,509,209,509,209,509,209,209,3428,6168,28168,6168,208,6168,284,2016,208,6168,2064

C. The Plaintiff appealed and filed an appeal with the Tax Tribunal, but was dismissed on October 31, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 2 and 3 (including branch numbers for those with additional numbers; hereinafter the same shall apply), Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The key issue amount of the Plaintiff’s assertion is that the Plaintiff’s sales of the product directly related to the Plaintiff’s sales of the product, as it constitutes part of the preemptive benefit items presented to the owner of the product, along with the estimate of the product, in order to obtain the prior owner’s approval in supplying the product subject to the prior owner’s approval, and has a direct impact on the selection of the preemptive part.