1. The Defendant’s penalty tax of KRW 63,94,930, global income tax of KRW 22,682,576, which reverts to the Plaintiff on September 1, 2013.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “instant company”) is a company incorporated on June 5, 2009 and engaged in clothing wholesale business and interior construction business.

B. In February 2009, the instant company issued sales tax invoices by entering into a contract with Daz Co., Ltd for KRW 135,364,000 (hereinafter “instant construction”) and received purchase tax invoices (hereinafter “instant tax invoices”) by entering into a contract with Daz Co., Ltd for KRW 133,00,000 as the supply value of the instant construction to Dazwon Co., Ltd. (hereinafter “Urban Development Interest”).

C. As a result of the investigation of value-added tax with respect to the instant company from May 24, 2010 to June 14, 2010, the head of Yeongdeungpo tax office: (a) determined that urban development had not been subcontracted the instant construction; and (b) determined that urban development had not been awarded a subcontract for the instant construction; and (c) issued a disposition imposing value-added tax of KRW 28,965,330 on the instant company by deducting the input tax amount from the input tax amount, by deeming the instant tax invoice as a processing tax invoice without real transaction; and (d) excluded the proceeds of supply KRW 146,30

Accordingly, the head of the Yeongdeungpo District Tax Office imposed corporate tax of KRW 11,585,300 on the instant company for the business year 2009 (the above imposition disposition and the disposition of corporate tax are referred to as the “prior disposition”), and disposed of the amount equivalent to non-deductible expenses as a representative bonus and notified the Defendant of the disposition as taxation data on August 17, 2010.

From June 5, 2009 to October 20, 209, the Defendant issued a revised notice on September 1, 2013, of the global income tax of 63,994,930 won to the Plaintiff on September 1, 2013, in addition to the Plaintiff’s income amount that was served as the representative director of the instant company as the representative director of the instant company.

(hereinafter referred to as "the disposition of this case". (e)

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on March 11, 2014, but was dismissed on June 3, 2014.