Plaintiff (Law Firm Squa, Attorneys Park Young-chul, Counsel for the plaintiff-appellant)

The Director of Gangnam District Office

October 31, 2014

Seoul Administrative Court Decision 2013Guhap5291 Decided December 6, 2013

1. The plaintiff's appeal is dismissed.

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

The judgment of the court of first instance is revoked. The Defendant’s disposition of reduction or correction of capital gains tax of KRW 176,861,731 and securities transaction tax of KRW 9,875,027, which the Plaintiff on December 1, 2011, shall be revoked (the “........,” stated in the petition of appeal and the petition of appeal, appears to have been written in writing on December 1, 201).

1. cite the reasoning of the first instance judgment;

This judgment is based on the reasoning of the judgment of the court of first instance, except where the following is added, and thus, it is based on Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

(1) From No. 2 to No. 16, “after the receipt” is added to “after the completion of the change of entry of the instant shares to Nonparty 1 (the fact that there is no dispute).”

② On the 8th page, the legal doctrine stated in the Supreme Court Decision 2001Du1536 Decided October 25, 2002, etc., presented by the Plaintiff as the basis of the Plaintiff’s assertion added “the fact that it does not apply to cases where a subsequent modification of contractual terms is made according to an agreement between the parties concerned,” as in the instant case.

2. Conclusion

Therefore, the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.

Judges Cho Jong-tae (Presiding Judge)