1. The Defendant (Counterclaim Plaintiff) paid KRW 27,893,227 to the Plaintiff (Counterclaim Defendant) and its related amount from January 6, 2016 to October 13, 2016.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On December 20, 2007, the Defendant obtained a construction permit for warehouse facilities on the land listed in the attached Table 1, 2, 4, and 3 (hereinafter collectively referred to as “instant land”) listed in the attached Table 1 List 1, 1, 2, and 209 square meters (the aforementioned two parcels were divided and land categoryed with each land listed in the attached Table 1, 4, and 6), and the land listed in the attached Table 1 List 3 (hereinafter referred to as “instant land”), but did not prepare construction costs.

B. From that point of view, the Defendant came to know of E around 201 and agreed to sell to him the right to newly construct a warehouse on the instant land and its ground. On July 201, 201, the Plaintiff, the wife of E, as the buyer, prepared a sales contract with the content that the Defendant sells the instant land to the Plaintiff for KRW 1,480,000,000, and entered into a special agreement with the Plaintiff on August 9, 201 with respect to the said sales contract, as follows:

(1) The buyer bears all public charges incurred from civil engineering works. (2) The buyer bears the burden on the buyer. (3) The buyer bears all public charges incurred from civil engineering works.

3) The taxes, public charges, etc. imposed due to land development shall be determined as follows: ① Acquisition tax for land category change (the first class 2 of the return form shall be borne by the seller up to KRW 1,480,00,000 per square year by the seller, and the buyer shall be fully responsible from KRW 1,480,000 per square year by the buyer.

② The Defendant bears the refund of development gains from the seller’s average KRW 1,400,000 per square year, and the purchaser is fully responsible for at least KRW 1,400,000 per square year.

③ All taxes and public charges generated from land development shall be borne by the Defendant of the seller up to KRW 1,480,000 per square year by the buyer, and the buyer shall be liable from at least KRW 1,480,000 to the total amount of KRW 1,480,000.

④ 20% of the transfer tax is reduced by the Defendant’s reduction of 1,480,00,000 won per usual account, and the Plaintiff’s reduction of 1,480,000 won per usual account.