1. The Defendant’s corporate tax of KRW 12,441,220 for the Plaintiff on November 14, 2016 and corporate tax of KRW 757 for the year 2012 for the Plaintiff.

1. Details of the disposition;

A. On June 16, 2010, the Plaintiff established B (hereinafter “instant corporation”) for the purpose of developing electronic equipment and parts, wholesale and retail business, etc.

At the time, the total number of shares issued by the instant corporation was 2,000 shares (amounted to 5,000 shares) and the Plaintiff, who was appointed as an in-house director, owned all the shares.

B. On September 6, 2011, registration was completed to the effect that the Plaintiff resigned from an internal director of the instant corporation, while registration was completed on the same day that the Plaintiff resigned from the audit of the instant corporation on January 5, 2012.

C. The instant corporation did not pay corporate tax for the year 2012 and the value-added tax for the year 201 and 1 and 2012.

On November 14, 2016, the Defendant: (a) designated the Plaintiff as the secondary taxpayer and notified the Plaintiff of the payment of corporate tax and value-added tax (hereinafter “instant disposition”); (b) as seen subsequent to the instant disposition, the Defendant made ex officio correction that reduces part of the corporate tax and value-added tax during the instant lawsuit; (c) however, the subject of the instant disposition is still the subject of the instant disposition).

On December 28, 2016, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal.

E. On July 28, 2017, when the instant lawsuit was pending, the Defendant confirmed that some of the penalty taxes (e.g., the sound portion of the table below) were imposed, and corrected ex officio the instant disposition by reduction.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 3, Eul evidence 1 to 4, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1 transferred the instant legal entity to C around September 5, 201, and thereafter transferred the same.