1. Acquisition tax assessed against the Plaintiff on July 24, 2013, KRW 149,201,540, local education tax; and KRW 13,806,020, which was assessed against the Plaintiff.

Details of the disposition

A. On December 30, 201, the Plaintiff is a corporation established to convert the place of business that was the former representative director of the Plaintiff, B, from July 25, 1993 to C, as a corporation.

B. The Plaintiff’s capital is KRW 350 million (share 70,000 x face value 50,000) and the Plaintiff’s statement of change in stocks, etc. (Evidence 2-2) stated as follows: B’s capital is KRW 1.5 million (21,000) and D’s KRW 1575 million (31,500) and E’s KRW 87,500 (17,500).

다. 원고는 2012. 2. 14. B과 사이에 C의 사업에 관한 일체의 권리의무를 포괄적으로 양수한다는 내용의 사업양도양수 계약(갑 제6호증, 이하 ‘이 사건 계약’이라 한다)을 체결하였는데, 그 걔약서의 주요 기재내용은 다음과 같다.

The purpose of this contract is to carry over the transfer income tax under Article 32 of the Restriction of Special Taxation Act and to convert the corporation subject to the exemption of acquisition tax under Article 120(5) of the same Act by transferring the whole rights and obligations of the company under B (C representative) by the plaintiff comprehensively by transferring the business under Article 6(6) of the Value-Added Tax Act.

Article 2 (Succession to Business) All transaction partners who are in transactions B as of the date of business transfer or acquisition shall accept and guarantee continuous transactions by the plaintiff, and if the products manufactured and sold in B are returned after the date of business transfer or acquisition, they shall be accepted and processed under the responsibility of the plaintiff.

Article 3 (Transfer and Receipt Assets, Liabilities, and Record Date) The Plaintiff shall take over the total assets and total liabilities on the books of the same B (C) as of December 31, 201 on the date of transfer and acquisition as of December 31, 201, and the details of assets and liabilities subject to transfer and acquisition shall be as shown in attached Form.

The value of transfer or acquisition shall be 241,542,024 won, less the total amount of liabilities from the total amount of assets under Article 3.

Provided, That the methods of evaluating assets and liabilities shall be 1.