1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. On September 30, 2009, the Plaintiff merged C&C Co., Ltd. (hereinafter “CB”).

B. On July 31, 2012, the Plaintiff: (a) deemed that the cause for bad debt occurred to KRW 1,072,240,236,525 (hereinafter “instant sales claim”) with respect to sales claim 7,674,96,525 won; and (b) the amount of sales claim 8,747,236,525 won (hereinafter “the instant sales claim”) with respect to the UNMtech Co., Ltd. (hereinafter “UNFCCC”); and (c) when calculating the amount of corporate tax for the business year 2010, the Plaintiff filed a claim for rectification from the output tax amount for the business year 2010 to deduct the bad debt tax amount of KRW 7,952,03,250; and (d) to seek the reduction of the bad debt tax amount of KRW 795,203,320 from the output tax amount for the second period of the value-added tax for the business year 2010.

C. On September 13, 2012, the Defendant rejected the Plaintiff’s claim for correction on the ground that the bad debt amount of the instant sales claim constitutes deductible expenses for the business year 2009, which belongs to the date of the registration of the merger pursuant to Article 19-2(4) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 21935, Dec. 31, 2009; hereinafter the same) and should be deducted from the output amount of value-added tax for the second period of

(hereinafter “instant disposition”) D.

On December 5, 2012, the Plaintiff filed an appeal with the Tax Tribunal, and was dismissed on March 20, 2014.

[Ground of recognition] Unsatisfy, Gap evidence Nos. 1 and 2 (including paper numbers; hereinafter the same shall apply)

2. Whether the instant disposition is lawful

A. The summary of the Plaintiff’s assertion 1 was that the collection of the instant sales claim was not finalized as follows, and thus, it cannot be deemed as bad debts at the time of the merger.

Even if a disposition on deficits of national taxes has been made by the head of the competent tax office, the bad debt cannot be recognized unless it is confirmed whether the claims can be recovered.

The Cub has sold the goods to the link business and the UNMtech as the reservation of ownership.