1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the intervenors.

1. The facts under the disposition of this case do not conflict between the parties, or are recognized by comprehensively considering the overall purport of the pleadings as follows: Gap evidence Nos. 1, 2, 5, 9, 11, 12, 14, Eul evidence Nos. 1 through 6, 13 through 19 (including any number), and evidence Nos. 1, 2, 5, 9, 12, 14.

[1] Around May 2001, G registered as a business operator with the trade name of “E” and operated “O” in the accommodation located in Songpa-gu Seoul Metropolitan Government J. Around July 2009, G obtained a new construction permit for the “I Tourist Tourist” (hereinafter “the instant tourist hotel”) with the 5th underground or above-ground 14 floors on the above land (hereinafter “the instant tourist hotel”).

On the other hand, D was appointed as the representative director of C Co., Ltd. (hereinafter “instant company”) on April 28, 2008, and was reappointed on April 28, 201.

Between G and G on December 15, 2011, the instant company drafted a contract (Evidence A No. 11) under which the construction of the instant tourist hotel will be supplied to approximately KRW 3,740,000,000 (including value added tax).

As a matter of principle, the above contract states that the flag shall be once a month and shall be paid on the 10th day of the following month by the fifth day of each month (Article 10(7)). On December 15, 201, the instant company written a contract (including value added tax) under which the interior works of the instant tourist hotel shall be supplied to substitute gold 6,050,000,000 won (including value added tax) between G and G.

The above contract states that all documents, specifications, drawings, and construction estimates entered into between H and G as of November 16, 201 are documents of the above contract between the instant company and G (Article 1). G obtained approval for use on December 6, 2012 with respect to the instant tourist hotel, and completed registration for the preservation of ownership on December 11, 2012.

[2] The instant company included KRW 17,567,987,539 in the sales statement of profit and loss in the business year 2012 (from January 1, 2012 to December 31, 2012).

The instant company filed a corporate tax return for the business year 2012, and KRW 6,101,60,600 out of the above construction income of KRW 17,567,987,539 (hereinafter “instant company”).