1. On September 2, 2014, the director of the Gangnam-gu Tax Office levied an additional tax of KRW 306,246,200 on the capital gains tax reverted to Plaintiff C for the year 2008.

1. Details of the disposition;

A. On March 30, 2002, the Plaintiffs acquired the instant G hotel building (hereinafter “instant real estate”) from D and E on March 30, 2002, 424m2 and its ground G hotel building (hereinafter “instant real estate”).

B. From March 8, 2004 to May 3, 2004, the director of the Seoul Regional Tax Office conducted a tax investigation on the source of the real estate acquisition fund of this case and whether the transferor had reported or underreported transfer income through false contracts, etc. (hereinafter referred to as the "first tax investigation") with respect to the Plaintiff A and B, and received KRW 304,00,000 out of the acquisition fund of the real estate of this case from Plaintiff B who is his spouse, and found that Plaintiff B underreported the transfer income of the H apartment of Seoul Seocho-gu. Accordingly, he imposed the relevant taxes on Plaintiff A and B around that time.

C. The Plaintiffs transferred the instant real estate to I on February 1, 2008.

The Plaintiffs reported the transfer income amount to the competent tax authority based on the sales contract (hereinafter “the sales contract of KRW 5.3 billion”) that purchased the instant real estate from D and E in total in relation to the said transaction, and paid the corresponding transfer income tax.

E. From November 16, 2009 to December 8, 2009, the director of the Seoul Regional Tax Office has conducted a tax investigation as to whether the acquisition value of the instant real estate, which served as the basis for the transfer income amount reported by the Plaintiffs, is appropriate, etc.

(f) The director of the Seoul Regional Tax Office recognized that the transfer value and the acquisition value were properly reported as the actual transaction amount, but found that part of the necessary expenses was excessively appropriated. Based on the result, the director of the Geumcheon District Tax Office revised the transfer income tax for the year 2008 for the plaintiffs A and B, and paid the increased tax amount for the above plaintiffs (Plaintiff A18,649,457, plaintiff B16,676,854).