1. Revocation of the first instance judgment.

The Defendant’s global income tax for the Plaintiff on August 3, 2017 14,303.

1. Details of the disposition;

A. On August 31, 2012, B Co., Ltd. (hereinafter “instant Company”) was established with the Plaintiff (14,000 shares, 35%) E (2,00 shares, 55%) and F (4,00 shares, 10%) as shareholders, and closed on March 24, 2014.

B. From the date of establishment of the instant company, the Plaintiff served as a representative director and an intra-company director on February 27, 2014, and resigned from the representative director and the intra-company director.

C. On August 30, 2012, at the time of the incorporation of the instant company, the Plaintiff borrowed KRW 200 million from C to pay as capital for the establishment of the instant company.

On September 3, 2012, immediately after its establishment, the Plaintiff withdrawn the total amount of the above capital and repaid the above borrowed amount. D.

The company of this case included 191,00,000 won as provisional payment in the account books.

On July 15, 2013, the Plaintiff reported the amount of KRW 3,357,90 as the corporate tax base for the said provisional payment, which was the corporate tax for the year 2012.

E. The head of the Ulsan District Tax Office included the total of KRW 1,690,488, and KRW 191,00,000, and the amount of KRW 13,179,488, and the amount of KRW 13,179,00,00, which was reported without filing a tax investigation with respect to the instant company, in the gross income, and disposed of the said amount as bonus to the Plaintiff who was the representative director of the instant company, and notified the Plaintiff and the instant company of the change in the amount of income, and notified the Defendant of the income data recognized by the Plaintiff.

According to the above notification, on October 1, 2016, the defendant decided and notified the Plaintiff of KRW 73,446,510 of the global income tax for the year 2013.

F. The Plaintiff dissatisfied with this and filed an objection with the director of Daegu Regional Tax Office.

On January 19, 2017, the commissioner of the Daegu Regional Tax Office shall dispose of the estimated income amount as total bonus to the Plaintiff, who is the representative director of the instant company. However, the aforementioned provisional payment and recognized interest shall be disposed of to each shareholder according to the share ratio, and the tax base and tax amount shall be applied by 10% of the additional tax for underreporting, which is not 20% of the non-reported additional tax.