1.(a)

On May 27, 2010, the Defendant imposed global income tax of KRW 90,374,314,620 (including additional taxes) on the Plaintiff in 199.

1. Details of the disposition;

A. (1) On December 26, 1987, the Plaintiff established C (hereinafter “C”) on August 17, 1994, and established C (hereinafter “D”) on January 31, 2001 by combining B and C’s business division, and serves as the representative director, respectively.

B, C, and D were exported to E (hereinafter referred to as the “E”) both in the form of sealing produced at a plant located in Korea and China.

(2) On May 21, 1996, the Plaintiff established F (hereinafter referred to as “F”), G on August 27, 1997 (hereinafter referred to as “G”), and H on October 4, 2002 (hereinafter referred to as “H”), respectively, by investing USD 100,000 in Hong Kong by means of direct overseas investment.

As follows, F and G exported the salary class category manufactured in China to E, and after D and H were established, D supplied the salary class type D supplied by H from suppliers in Hong Kong to E.

B. The Defendant’s taxation disposition and the Plaintiff’s objection (1) established the Seoul Regional Tax Office’s tax investigation on the Plaintiff from February 25, 2010 to June 25, 2010, and established I, J, K, L (hereinafter “each “I, J, K, K”, and L”) in Malaysia, Malaysia, etc., and Ma, N, N,O (hereinafter “M”, “N,” and “O” were transferred funds of the Hong Kong corporations to each of the corporations of the Hong Kong corporations or received dividend income in lieu of dividend income. The Defendant notified the Defendant of the following taxation data:

(Specific Details are as indicated in the annual omission income by type of “attached Form”, “tax base and tax summary table,” and the dividend income paid in the name of the second-name shareholder by adding up Nos. 5 and 6 below, classified as dividend income. Of the annual omission income by type of “annual omission income” in attached Form 1, corresponding thereto.