1. On July 1, 2014, the Defendant imposed global income tax of KRW 7,998,256 (including additional taxes) on the Plaintiff for the year 201.

1. Details of the disposition;

A. From the end of 2007 to the end of 2013, the Plaintiff was provided with security, such as collateral on real estate, by 13 debtors, and lent money to them 14 times.

On July 1, 2014, the Defendant confirmed that the Plaintiff did not file a global income tax on the interest (including KRW 24,250,000, KRW 47,200,000) that the Plaintiff received from the debtor, and that this was considered as a type of non-business loan under the Income Tax Act, and notified the Plaintiff on July 1, 201, of the rectification of the global income tax for the year 201 and the global income tax for the year 2012, KRW 14,275,640 (including the additional tax).

(hereinafter “instant disposition”). (b)

The Plaintiff appealed and filed a request for examination with the National Tax Service on September 16, 2014, but was dismissed on December 23, 2014.

[Ground of recognition] Facts without dispute, Gap Nos. 1, 3, 4, Eul evidence No. 1 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion was a credit service provider who was registered with the competent authority or did not make a business registration at the competent tax office. However, since 208, the Plaintiff had been running a business continuously and repeatedly lending money to many persons who were introduced by the branch or the branch for more than four years.

Therefore, since the interest that the Plaintiff received from the debtor should be deemed business income, the disposition of this case, which is imposed by deeming it as the interest of non-business loan, is unlawful.

(b) as shown in the attached Form of the relevant statutes;

C. According to Article 16 (1) 11 and (3) of the Income Tax Act and Article 26 (3) of the Enforcement Decree of the Income Tax Act, profits from non-business loans are interest or fees that a person who does not intend to lend money for business purposes receives by temporary or incidental lending of money.

Any monetary lending shall be the amount of profit-making, continuity, repetition, length of the transaction, and the amount of the lending.