The judgment of the first instance, including the claims expanded in the trial, shall be modified as follows:

1. The instant lawsuit is filed.

1. Basic facts

A. On March 2008, the Plaintiff entered into a partnership agreement with Nonparty E and C to jointly establish and operate a postnatal care center.

The Plaintiff’s share ratio under the above agreement is 40%, and 10% of which is the share held in title trust by the Defendant, and the Plaintiff has paid the Defendant profits equivalent to 40% of its external share out of the profits accrued from the operation of the Postnatal Care Center, which is equivalent to 10% of the Defendant’s actual share.

B. The Plaintiff and the Defendant entered into each of the partnership agreements on the establishment and operation of Eunpyeong J Postnatal Care Center (10% of the Defendant’s shares), Magjin J Postnatal Care Center (10% of the Defendant’s shares), and JJ Postnatal Care Center (5% of the Defendant’s shares) with the Government of Jung-gu.

(The above four postnatal care centers shall be hereinafter referred to as each of the instant postnatal care centers).

On July 29, 2011, the Defendant transferred each share to each of the postnatal care centers of this case owned by himself to the Plaintiff.

On September 27, 2011, JJ changed the operation form to Co., Ltd.(J Postnatal Care Center Co., Ltd. and Representative Co., Ltd).

On May 2012, the Plaintiff filed a revised return on the tax base for year 2011 with respect to Pyeong Postnatal Care Centers, JJ Postnatal Postnatal Care Centers, and JJ Postnatal Postnatal Postnatal Care Centers, and paid KRW 20,291,05, global income tax, KRW 52,932,438, global income tax, KRW 13,280,462, global income tax, KRW 8,672,610, and KRW 6,948,734, global income tax, KRW 13,716,450, and KRW 20,65,814, in relation to PJ Postnatal Postnatal Care Centers, respectively.

E. The Seoul Regional Tax Office: (a) conducted a tax investigation with respect to the Postnatal Care Center from October 29, 2012 to November 27, 2012; and (b) during the taxable period from January 1, 2009 to September 26, 201; and (c) issued cash receipts for the Postnatal Care Center.