1.The judgment of the first instance shall be modified as follows:

The defendant's business year of July 13, 2000 against the plaintiff on July 13, 2009.

1. Case progress and scope of trial of this court;

A. The relationship between the Plaintiff and related parties, etc. 1) The Plaintiff is a company that mainly engages in investment in, and financing for, small and medium venture businesses, and is called the Asia Pacific Lance Ltd. (hereinafter referred to as APAI) on May 7, 1996 within Malaysia, which is a tax avoidance area.

) Neither on February 28, 2000 nor on February 28, 200, Ethical Fund, Ethical Investment Livest Investment Ld. hereinafter referred to as IIL.

2) On the other hand, on June 21, 1999, the Plaintiff, Nonparty A, and Nonparty B jointly invested and established C Co., Ltd. (hereinafter “C”).

B. Section IIL’s acquisition of forfeited stocks by wrongful calculation 1) The secondL participated on March 20, 200 and accepted KRW 158,000 per share of forfeited stocks at KRW 158,000 per share. Seven persons, including A, etc., who are shareholders of 63,333.33 share of forfeited stocks, among the 70,000 share, including the Plaintiff and the former Corporate Tax Act (amended by Act No. 6293, Dec. 29, 200; hereinafter the same shall apply.

Article 52 of the Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 17033 of Dec. 29, 2000)

A) A person with a special relationship stipulated under Article 87 (hereinafter “specially related person”).

(2) On January 18, 2002, the Defendant: (a) deemed that the Plaintiff acquired the forfeited stocks as above; (b) assessed the value per share of the forfeited stocks as KRW 43,200,00; and (c) on May 2, 200, the Plaintiff acquired the forfeited stocks as above to the above specially related person by allocating the profits of KRW 8,032,50,000 [158,00-43,250] x 70,000, which is equivalent to the difference between the value of the subscribed stocks and the above appraised values x (i.e., the unfair act under Article 88(1)8 (b) of the Enforcement Decree of the Corporate Tax Act; (b) deeming the difference to be an object of denial to be the gross income and increase corporate tax by disposing other than the forfeited stocks; and (d) sold the forfeited stocks to the Plaintiff on May 22, 2002.