1.The judgment of the first instance shall be modified as follows:

The Defendant's business year of July 13, 2000 against the Plaintiff.

1. Circumstances and progress of the disposition;

A. On May 7, 1996, the Plaintiff, including the relationship between the Plaintiff and related companies, was a company that mainly engages in investment in, and financing to, small and medium venture businesses, and was established in Malaysia, a tax avoidance area, for the purpose of establishing the Asia Pacic Alcic Investment Ltd. (hereinafter “AP AI”), AP AI on February 28, 200, respectively.

On the other hand, on June 21, 1999, the plaintiff, the non-party A, and the non-party B jointly invested to establish C Co., Ltd. (hereinafter referred to as "C").

B. On March 20, 200, IIL, a wrongful calculation based on the acquisition of forfeited stocks of IIL, participated in the capital increase issued by C (State) on March 20, 200, and accepted KRW 158,000 per share to KRW 150,000 per share. 7 persons, including A, etc., who are shareholders of 63,333.33 shareholders of forfeited stocks, are in the position of a person having a special relationship under Article 52 of the Corporate Tax Act with the Plaintiff and Article 87 of the Enforcement Decree of the Corporate Tax Act (hereinafter “specially related person”).

On January 18, 2002, the Defendant: (a) deemed that the Plaintiff acquired the forfeited stocks as above; (b) assessed the value per share of the above forfeited stocks as KRW 43,200; and (c) accepted the forfeited stocks as above by the Plaintiff on January 18, 200, based on the apportionment of the profits of KRW 8,032,50,00 ( KRW 158,000-43,250 x 700 x 8,000 which is equivalent to the difference between the value of the subscription and the value of the above appraised stocks; (b) deeming the difference to be an unfair act under Article 88(1)8 (b) of the Enforcement Decree of the Corporate Tax Act, and thus, (c) increased corporate tax by disposing of other forfeited stocks; and (d) on May 22, 2002, the Plaintiff acquired the forfeited stocks as above KRW 70,000 per share to the above specially related person; and (d) determined the difference between the forfeited stocks and the Plaintiff’s equivalent to KRW 636363636,63636.3636.3636.