1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

3. Of the judgment of the court of first instance, the judgment of the court of first instance is deemed to have been rendered.

1. The reasons why the court should explain this part of the disposition are the same as the entry of the part concerning "1. The reasons why the disposition was taken" as stated in the second-fourth of the judgment of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. Whether the instant disposition is lawful

A. The gist of the Plaintiff’s assertion is that the instant contract was concluded with the U.S. corporation “G” and the “H and its shareholders,” and thus, it is irrelevant to F, a domestic corporation, and the instant contract cannot be deemed to have been rescinded, and it cannot be deemed that USD 4 million paid to H was confiscated as penalty for breach of contract. Therefore, the disposition imposing corporate tax for F in 2010 is unlawful.

In addition, A was not informed by the original defendant of the reason for the instant disposition.

Therefore, the instant disposition should be revoked as it is unlawful.

B. The grounds for this part of the relevant statutes are as stated in the part of the “related statutes” written in the 4-5 pages of the judgment of the court of first instance (including attached documents). Thus, this part of the relevant statutes is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

C. The reasoning for the court’s explanation as to this part of the contract of this case is as stated in the five pages of the judgment of the court of first instance, except for the modification of the pertinent part as follows. Thus, this part of the contract of this case is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

5. The term "the first instance court" shall be added to the left side of the 5th parallel "witness".

The 5th day below the 5th day "this court" shall be regarded as "the first instance court".

2) The agreement cancellation of the instant contract and the forfeiture of penalty therefrom) contract cancellation or rescission of the contract, regardless of the existence of the right of rescission, shall terminate the validity of the existing contract by mutual agreement between the parties, and shall begin from the beginning.