1. The plaintiff's claim of this case is dismissed.

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

1. Details of the disposition;

A. The Plaintiff was a corporation established on June 20, 2005 by having invested 100% of its capital by the Plaintiff, and engaged in the manufacturing business of electrical parts contact materials. In 2006 and 2007, the Plaintiff applied for a tax credit for special taxation and research and human resources development expenses for small and medium enterprises under the Restriction of Special Taxation Act at the time of filing corporate tax return in 2006 and 2007, and was subject to a corporate tax reduction or exemption.

B. The Defendant: (a) deemed that the Plaintiff did not meet the actual independent requirements under Article 2(1)3 of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 19329, Feb. 9, 2006; Presidential Decree No. 20620, Feb. 22, 2008; Presidential Decree No. 19189, Dec. 27, 2005) and Article 3 subparag. 2 of the former Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 19189, Dec. 27, 2005; (b) deemed that the Plaintiff did not constitute a small and medium enterprise from the business year of 2006; (c) excluded the application of the provisions on reduction and exemption and deduction of the tax amount related to small and medium enterprises under the Restriction of Special Taxation Act; and (d) notified the Plaintiff on February 14, 2011, the corporate tax accrued in 2007.

(hereinafter “instant disposition”). C.

On May 6, 2011, the Plaintiff filed a request for examination with the Commissioner of the National Tax Service on May 6, 2011, but was dismissed on November 30, 2011.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 and 2, each entry in 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. (1) The Plaintiff’s assertion (1) Article 2(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 19329, Feb. 9, 2006; hereinafter “the Plaintiff’s assertion”) provides for the scope of small and medium enterprises subject to special taxation related to small and medium enterprises and requires substantial independence to conform to Article 3 subparag. 2 of the Enforcement Decree of the Framework Act on Small and Medium Enterprises. In applying Article 2(5) of the same Act, companies shall be the Framework Act on Small