A donation contract concluded on January 25, 2019 between the Defendant and B shall be KRW 146,281,405.

1. Facts of recognition;

A. Plaintiff B’s taxation claim 1) B opened and operated a photographic business of “C” on March 1, 2012, and closed its business on December 20, 2018. On February 18, 2017, the Defendant’s name, the spouse of the Plaintiff, closed its business on November 30, 2018 while opening and operating a business of “D” in the same type of business. (ii) The head of the tax office affiliated with the Plaintiff, from December 3, 2018 to December 7, 2018, corrected the Plaintiff’s representative from “Defendant” to “B.”

3) From February 12, 2019 to March 31, 2019, the Plaintiff-affiliated Tax Office issued a general consolidated investigation on B, and confirmed that B omitted income amount due to deposit in the name account in the name of a relative, such as the Defendant, mother, and wife, and then notified the Plaintiff of the decision to impose the global income tax of KRW 607,376,30 on May 31, 2012 and the total amount of KRW 45,61,180 on the 607,376,30, and the total amount of value-added tax of KRW 11 to 205,61,00 on the 20th of the year 205, the Plaintiff-affiliated Tax Office imposed the global income tax on the 20th of the year 205, without filing a revised tax return on the 2018 and the aggregate amount of value-added tax on the 20th of the year 2019.

2) [Attachment] The details of arrears (unit: the notified amount of arrears due on the date on which the tax liability to revert the original tax item is established.