1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The Plaintiff submitted to the Defendant a donation receipt (hereinafter “the donation receipt in this case”) with the content that, while working for Hyundai B&S T&T Co., Ltd, the Plaintiff donated KRW 4.3 million in the year 2009 to D (representative E; hereinafter “the instant temple”) which is a religious organization affiliated with C located in Busan Northern-gu, Busan (hereinafter “the instant temple”), KRW 4.8 million in the year 201, KRW 5.5 million in the year 201, and KRW 5.4 million in the year 2012, and received a donation deduction from the Defendant on global income tax for the year 209, 2010, 2011, and 2012.

B. On July 2014, the director of the North Busan District Tax Office investigated the tax offense against the instant temple: (a) deemed that the instant temple issued donation receipts in a false and excessive manner; (b) accused the Plaintiff as a violation of the Punishment of Tax Evaders Act; and (c) notified the Defendant of taxation data that the Plaintiff’s contribution to the instant temple was not subject to income deduction.

C. On May 1, 2014, the Defendant notified the Plaintiff of KRW 975,235 of global income tax for the year 201, KRW 956,324 of global income tax for the year 201, and KRW 1,061,869 of global income tax for the year 2009, and KRW 1,048,833 of global income tax for the year 2010, respectively.

On the other hand, E was indicted by violating the Punishment of Tax Evaders Act (Act No. 201452, Jun. 11, 2015) in Busan District Court Decision 2014Da10412, and was convicted by the court of first instance on June 11, 2015. However, on February 16, 2016, the appellate court rendered a not-guilty verdict on the charges of violating the Punishment of Tax Evaders Act (Seoul District Court Decision 2015No2042, hereinafter “instant criminal judgment”), and the above judgment became final and conclusive as it is by the Supreme Court’s dismissal of appeal on June 23,

(Supreme Court Decision 2016Do3582). The part partially acquitted includes the charge of committing an offense against the Plaintiff in relation to the issuance of donations in this case against the Plaintiff.

E. On September 9, 2016, the Plaintiff’s criminal judgment on the instant case rendered to the Defendant on September 9, 2016 constitutes grounds for filing a subsequent claim for rectification under Article 45-2(2)1 of the Framework Act