1. The Defendant imposed corporate tax of KRW 6,715,969,995 (including additional tax) on the Plaintiff on February 1, 2013, and 4.

1. Details of the disposition;

A. On February 22, 200, the Plaintiff was established with the purpose of apartment and housing sales business as of February 22, 200, and the Plaintiff is the concessionaire of the Hansi-Eup apartment (including total 12 Dong, total 937 households, commercial building types 1; hereinafter “the apartment of this case”).

B. In the business year of 2006, the Plaintiff sold all of the instant 937 households, and reported corporate tax by including the sales proceeds calculated according to the progress rate of work until the business year of 2006 to 2008 in the gross income for the pertinent business year.

However, in 2009, the Plaintiff determined that the sales contract of 182 households among the apartment buildings of this case (hereinafter “the instant 182 households”) was de facto rescinded in light of the circumstances such as intermediate payment and unpaid balance, etc., and that the Plaintiff reported and paid corporate tax of 3,245,784,784,973 won and the sales revenue of 182 households related to the instant 182 households, not including the sales revenue of 104,430,272,570 won and the sales cost of 74,618,826,785 won and the sales cost of 74,61

C. On October 1, 2012, the director of the Seoul Regional Tax Office conducted a tax investigation on the Plaintiff. The sales contract for the 182 household of the instant case was not rescinded in the business year 2009, and the relevant gross income and deductible expenses should be reflected in the profit and loss of the business year to which the date of cancellation belongs, notified the Defendant to include the sales proceeds and the sales cost in the gross income and deductible expenses for the business year of 2009 and to impose them (in addition, the tax base has increased by 27,191,216,394 won). On February 1, 2013, the Defendant notified the Plaintiff of the increase in the corporate tax amount of 8,414,748,120 (including additional tax) for the business year of 209.

On May 7, 2013, the Plaintiff appealed and filed a tax appeal with the Tax Tribunal.

The Tax Tribunal partially accepted the Plaintiff’s claim on June 9, 2015, and specifically, the instant 182 households are classified as follows, and ① the Plaintiff.