1. The Defendant imposed corporate tax amounting to KRW 10,639,943,484 on the Plaintiff on July 1, 2013, KRW 335,354,028, which the Defendant imposed on the Plaintiff on July 1, 2013.

1. Details of the disposition;

A. On March 16, 2006, the Plaintiff purchased land and buildings located in Gangseo-gu Seoul Metropolitan Government (hereinafter “instant real estate”) from the Handong Industry Co., Ltd. in order to carry on real estate leasing business, with the price of 34 billion won, and completed the registration of ownership transfer on the instant real estate on June 23, 2006.

B. On April 30, 2008, the Plaintiff entered into a contract to sell the instant real estate at KRW 70 billion (hereinafter “instant sales contract”) with C Co., Ltd. (hereinafter “C”), and completed the registration of ownership transfer on June 19, 2008 with respect to the instant real estate on June 19, 2008 without receiving any remaining purchase and sale amount.

C. On March 31, 2009, the Plaintiff reported KRW 278,124,958 as corporate tax for the business year 2008, by including the difference of KRW 70 billion and the book value of KRW 41,338,247,988 as well as the real estate value of KRW 28,61,752,012 as income (the profits from disposal of tangible assets) and adding the proper purpose business expenses to the deductible expenses, and adding the proper purpose business expenses to the deductible expenses, KRW 20,326,168,372 as well as KRW 1,212,613,200 as corporate tax for the business year 2008.

① The Defendant denied the Plaintiff’s total amount of KRW 1,417,285,109 and KRW 2,501,501,61,471 out of the interest paid for the Plaintiff included in deductible expenses for the business year 2007 as the interest paid for the borrowings used for profit-making business in deductible expenses for the business year 2008 and the amount of KRW 1,083,876,362 included in deductible expenses for the business year 208. ② The Defendant denied the Plaintiff’s deductible expenses on the grounds that the amount of interest paid for the borrowings used for profit-making business was not the interest paid for the borrowings used for profit-making business in deductible expenses, and denied the Plaintiff’s deductible expenses on the ground that the amount of KRW 20,326,168,372 included in deductible expenses for the business year 2008 and KRW 1,212,613,200 was not a corporation subject to the establishment of the reserve fund for proper purpose business for the business year.

E. The Plaintiff appealed and filed an objection on October 4, 2013, and the Defendant rendered a decision to additionally include KRW 1,797,784,000, including acquisition tax, etc. on October 30, 2013, in deductible expenses.