1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On December 12, 2007, six persons including the Plaintiff and Nonparty B (hereinafter “Plaintiff et al.”) entered into a contract on the transfer of stocks and management rights including 44,800 shares (24,80 shares owned by the Plaintiff and B, 5,200 shares owned by the Plaintiff, and 5,200 shares transferred by the Plaintiff et al. (hereinafter “D”) to Nonparty D Co., Ltd. (hereinafter “D”), and received down payment and intermediate payment of KRW 8 billion on January 10, 2008, and thereafter reported capital gains tax to the Defendant by applying the tax rate of 10%.

B. On December 14, 2010, B entered into a contract for acquisition of stocks that transfer 5,200 shares of C (10.4%) to Nonparty E Co., Ltd., and received the remainder KRW 1 billion on the date of the contract, and KRW 395,160,000 on December 24, 2012, and thereafter reported and paid the capital gains tax to the Defendant by applying 10% tax rate.

C. The Seoul Regional Tax Office: (a) conducted an investigation of stock fluctuation; and (b) determined that the time of the transfer of the instant shares and other outstanding shares is less than three years; (c) determined that the instant outstanding shares constituted other assets (real estate owned by a major shareholder and the stocks owned by a major shareholder) under Article 94(1)4 of the Income Tax Act; and (d) issued the instant disposition to correct and notify the Plaintiff of the transfer income tax amounting to 311,225,720 (including additional tax amounting to 59,81,454) for the year 2010, on May 15, 2013 by applying the cumulative tax rate.

The Plaintiff filed a tax appeal on the instant disposition on June 24, 2013, but was dismissed on October 21, 2013.

【Ground of recognition】 The fact that there has been no dispute, each entry of Gap1 or 4, the purport of whole pleadings

2. The Plaintiff’s summary of the claim was settled at January 10, 2008 at the time of the transfer of the instant shares, but the liquidation of the outstanding shares was conducted on December 12, 2007.