1. The Defendant’s transfer income tax of KRW 11,79,514,820 for the Plaintiff on June 13, 2012 (including additional taxes) for the year 2009.

1. Details of the disposition;

A. On November 23, 1984, the Plaintiff obtained a reclamation license for public waters from the Minister of Maritime Affairs and Fisheries with respect to Seo-gu, Busan (hereinafter “B”) on the basis of the former Public Waters Reclamation Act (amended by Act No. 3901, Dec. 31, 1986; hereinafter “former Public Waters Reclamation Act”). From January 1, 1987 to December 31, 1999, buried a site of 83,413 square meters in total as indicated in the following table with the approval of the completion of construction from the head of Busan Regional Maritime Affairs and Fisheries on August 29, 2001, buried a site of 21,675 square meters which is reverted to the State and the local government on August 29, 200, and acquired the ownership of D 20,037 square meters and E. 471 square meters in total (hereinafter “the landfill”).

D 1,409 K 1,409 K 1,409 K 1,085 C 1,467 K 1,409 K 1,085 C 1,037 E 20,037 E 1,700 G 870 G 6,805 H 12,714 Busan Metropolitan City 6,467 J. 1,409 K 1,409 K 1,085 M 1,037 E 41,701 small 61,738

B. On December 30, 2009, the Plaintiff transferred 41,701 square meters of E miscellaneous land (hereinafter “instant land”) to Dong Korea Port Co., Ltd. (hereinafter “Dong Korea Port”) in KRW 42,887,60,000, and reported and paid KRW 1,63,402,719 of the transfer income tax by deeming that it is impossible to verify the actual transaction price at the time of acquisition of the instant land at the time of filing a preliminary return on the transfer income tax on February 26, 2010, by deeming that the said transfer falls under a case where the actual transaction price cannot be confirmed at the time of acquisition of the instant land at the time of filing a preliminary return on the transfer income tax on February 26, 2010.

C. As a result of conducting a tax investigation on the transfer of the instant land from April 18, 201 to May 7, 2011, the Defendant deemed that the actual acquisition price of the instant land cannot be confirmed due to the lack of knowledge about the total construction cost for reclamation of the instant reclaimed land, and thus, the Plaintiff’s content of the return on capital gains tax applying the conversion price is appropriate.