1. The second preliminary claim added by this court before the remand is dismissed.

2. The Plaintiff’s total costs of litigation.

1. Basic facts

A. On January 23, 2009, F Co., Ltd. F (hereinafter “F”) added gold export business, futures investment business, and export business of precious metals, etc. to its intended business, and on July 15, 2009, Co-Defendant D was appointed as the representative director.

The F purchased gold in Korea from February 9, 2009 to June 2010, and exported gold bullion in the form of Alleybrid to Hong Kong.

B. F In the tax investigation and administrative litigation with respect to F, the F declared corporate tax by appropriating the purchase price of gold in the business year 2009 as KRW 309,830,057,518.

On September 6, 2010, F reported corporate tax by appropriating 12,517,530,851 won or more of the purchase price of high gold, the head of Sungdong Tax Office imposed corporate tax of 3,826,955,790 won for the business year 2009.

Accordingly, F filed a lawsuit seeking revocation of the disposition imposing corporate tax as Seoul Administrative Court 2012Guhap2287, but the claim was dismissed on April 19, 2013. The Seoul High Court appealed 2013Nu15981, but the appeal was dismissed on January 21, 2015 and became final and conclusive on February 10, 2015.

(hereinafter referred to as “related administrative case”. 【The grounds for revocation of the disposition imposing corporate tax” are without dispute; 【No evidence No. 18, 19, 25, 26, 28, 29, 84, 85, 99, 101, 103, 105, 112, 12, and 3-12 through 17 of the evidence No. 2-18, 19, 25, 26, 28, 29, 84, 85, 9, 101, 103, 105, 112, and 12 of the evidence No. 3-12 through 17 of the court witness I before remand, and the purport of the whole pleadings

2. Judgment on the second preliminary claim

A. During the process of the relevant administrative case, the Defendant agreed to the Plaintiff that “F will pay KRW 350 million to the Plaintiff when winning the relevant administrative case, and KRW 200 million to the Plaintiff when losing.”

(hereinafter “instant agreement”). Since the judgment against F in a related administrative case became final and conclusive on February 10, 2015, the Defendant is against the Plaintiff.