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

The director of the regional tax office of the defendant Triju on the plaintiff, (1) on October 2005.

1. Details of the disposition;

A. (1) Party status (1) The Plaintiff entered into a contract with a special purpose company (including a foreign corporation specializing in special purpose companies and asset-backed securitization business under domestic laws; including Loneone Star Fund III US LP; Loneoneoneoneone LP; hereinafter referred to as “Lone Star Fund III”); Loneoneone Lone Star Fund III Lone Star Fund III; and Loneoneoneone Lone Star Fund IV Lone Star Fund IV Lone Star Fund IV Lone Star Fund IV (hereinafter referred to as “Lone Star Fund IV; hereinafter referred to as “Lone Star Fund IV”); hereinafter referred to as “Lone Star Fund II, III, and IV”) invested in the Special purpose company, etc. (including special purpose companies and asset-backed business under domestic law; hereinafter referred to as “Lone Star Fund II”); and hereinafter referred to as “special purpose company or special purpose company specialized in asset-backed securitization; and hereinafter referred to as “special purpose company or special purpose company specialized in asset management”.

(2) According to the above asset management consignment agreement, the Plaintiff provided assets management, operation, and disposal of the securitization assets (hereinafter “asset management services”) and received assets management fees therefor. In addition to the asset management of the above special purpose company, the Plaintiff provided incidental services such as tax reporting services (hereinafter “incidental services”) on behalf of another company and received incidental service fees.

(3) The Hudson KRC (hereinafter “HALC”) is a corporation that provides Ludson’s Ludson’s LALC with investigation and asset assessment and consulting services for Lone Star Fund, and is the parent company of the Plaintiff.

B. The director of the regional tax office, which imposed corporate tax for the year 200 and 2001, deems the Plaintiff and the non-party special purpose company to have a special relationship under the Corporate Tax Act, applied the provision on the limit of entertainment expenses to the related parties under the proviso of Article 25(1)2 of the Corporate Tax Act. The amount exceeding the limit is excluded from deductible expenses as indicated in the following table, and the corporate tax was corrected and imposed on the Plaintiff on October 14, 2005, as stated in the notice of imposition and the notice of change of income amount.

part of the Gu.