The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Details of the disposition;

A. The Plaintiff is a juristic person established on October 15, 2004 and engaged in mid-term rental business, construction materials also and retail business. B constitutes the Plaintiff’s special related person as the Plaintiff’s representative director under Article 52(1) of the former Corporate Tax Act (amended by Act No. 14386, Dec. 20, 2016; hereinafter “former Corporate Tax Act”) and Article 87(1) of the Enforcement Decree of the former Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 12, 2016; hereinafter “Enforcement Decree of the former Corporate Tax Act”).

B. B, with the trade name of “C” on April 25, 1998, was engaged in construction machinery leasing business, and on October 15, 2004, the Plaintiff was established separately from the above individual business, and the Plaintiff is operating construction machinery leasing business in parallel with the Plaintiff up to the present day (hereinafter “C”). C.

On November 20, 2014, the Plaintiff concluded a sales contract with D and E to purchase each construction equipment of KRW 470,000,000, KRW 1991 and KRW 2 in food in 1996 (the above 1991 food crane is referred to as “the instant tea,” and the above 196 food crane is referred to as “96 food crane,” and the combined 1.4 billion total amount of KRW 1.45 billion (the value separate, KRW 45 million, KRW 96,000, KRW 95,000,000, KRW 1.500,000,000, KRW 96,000,000). The Plaintiff received the supply of each E-14,50,000,000 from D to “the supply of the E-14,500,000,000 won,” respectively.

EI G H/ German 1991 450,000,000 won, EI G H/ German 1996 KRW 950,000,000,000 for the annual supply of equipment number type DF G H/ German 1996 KRW 950,000,000 for 96

D. On January 6, 2015, the Plaintiff purchased the instant tea to D.