1. Of the judgment of the court of first instance, the part against the defendant exceeding the amount ordered to be paid below shall be revoked and above.

1. Basic facts

A. The Plaintiff is a company that operates textile manufacturing and sales business, and the Defendant has received delegation from the Plaintiff since 2001 to handle the Plaintiff’s tax return, bookkeeping agency, etc.

B. The Plaintiff reported corporate tax in 2006. (1) The Plaintiff’s operating income in 2006 was -106,598,843 won, 1,718,784,871 won, interest income was 367,628 won, and ordinary profit was 1,279,821,918 won. (2) The Defendant reported the Plaintiff’s corporate tax in 2006 as stated in the attached Form “Account” and calculated the reduced or exempted tax amount as 81,976,100 won by applying the reduction or exemption rate under the Restriction of Special Taxation Act to the profits, including the profits from the disposal of fixed assets (the method of calculating the reduced or exempted tax amount is as stated in the attached Form “the initial calculated tax amount”) and the Plaintiff finally calculated the reduced or exempted tax amount of KRW 81,976,100, and paid KRW 62,6533,733 won to the Plaintiff.

C. 1) The Daegu regional tax office pointed out in 2009 that the profits from disposal of fixed assets were not generated from the manufacturing industry, and thus, it did not impose corporate tax reduced or exempted, KRW 81,976,100 and additional tax KRW 20,190,713 on April 24, 2009. 2) The Plaintiff filed a request for a national tax trial on November 12, 2009 after filing an objection on August 28, 2009, but the request was dismissed on February 17, 2010, the Plaintiff paid both the corrected corporate tax and additional tax until May 4, 2010.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 12 (including branch numbers if there are branch numbers), the purport of the whole pleadings

2. The defendant's judgment on this safety defense is unlawful since the plaintiff's objection against additional tax, etc. should be subject to administrative litigation, and the lawsuit of this case filed against the defendant who is a certified tax accountant by civil litigation is unlawful.