The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Details of the disposition;

A. The Plaintiff is a company that manufactures and sells electrical distribution equipment, such as mix, location, and contact.

B. B is the representative director and in-house director of the Plaintiff, and C and D are in-house directors of each Plaintiff.

In addition, C is children of B, D is a partner of B.

C. The Plaintiff entered into a patent acquisition agreement with the content of acquiring a patent from B, C, and D (hereinafter “B, etc.”) as follows (hereinafter “instant acquisition agreement”).

(hereinafter referred to in paragraphs (1) through (6) of the Patent Act refers to “total patent”, and among them, the patent rights listed in paragraphs (2) through (6) of the said No. 2 through (6) refers to “a patent in dispute”, and where they are individually specified, “net0 patent”). The transfer price of the patent subject to transfer on the date of the transferor’s contract is 1 B of the transfer of 18 items including E, 500,000,000 won on December 31, 2014, 2015 3 C C C of KRW 115,00,000,000 won on February 27, 2015, G 310,000,000 KRW 4 H5 D on April 22, 2015.

D. The Plaintiff withheld and paid the income tax of B, etc. while paying the transfer price to B, etc. according to the instant transfer agreement.

In addition, the Plaintiff reported the corporate tax base by treating the depreciation costs of the pertinent patent in deductible expenses of KRW 101,250,250 in 2015, and KRW 135,000 in 2016.

E. From March 27, 2018 to June 16, 2018, the director of the regional regional tax office of Jungbu Regional Tax Office: (a) conducted a tax investigation with respect to the Plaintiff; and (b) as a result, determined that “All patent rights were directly developed and developed through the Plaintiff’s company-affiliated research institute, etc.; (c) the rights were reverted to the Plaintiff from the beginning; and (d) the Plaintiff again acquired the rights.”

F. Accordingly, (1) Article 106(1)1(b) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 29529, Feb. 12, 2019; hereinafter the same) against the Plaintiff on August 1, 2018.

on the basis of this item, the total transfer proceeds of patent rights.