1. The Defendant’s global income tax amounting to KRW 395,058,549 (including additional taxes) for the Plaintiff on May 10, 2016.

1. Details of the disposition;

A. A. Around April 201, the head of Samsung District Tax Office conducted a partial investigation of corporate tax on B (a mutual company C before the alteration; hereinafter “B”), and around July 2008, the Plaintiff and D were the representative director, published that they issued bonds with warrants of KRW 1 billion to E Co., Ltd. (hereinafter “E”), and subsequently, notified the head of Dongjak District Tax Office of the imposition of the comprehensive income tax on F on the amount equivalent to the interest of the instant case, on the ground that the Plaintiff and D were omitted from withholding the principal of the bonds with warrants and the interest of KRW 1.6 billion (hereinafter “interest of this case”) even though they repaid the F the principal of the bonds with warrants and the interest of KRW 1.6 billion.

B. F asserted to the head of Dongjak Tax Office that “self-employed shall arrange for the investment of KRW 1 billion in the purchase price of the bonds with warrants to G, and in return for the investment of KRW 40 billion in the purchase price of the bonds with warrants to receive 40% from the preemptive right of the bonds with warrants, and did not exercise the preemptive right and did not obtain any profit from the investment mediation. 80 million won repaid from B was returned to G, and 50 million won was arbitrarily invested in H Co., Ltd. (hereinafter “H”) and returned 200 million won to G with its own personal funds. It did not receive any consideration in the course of investment mediation, and the head of Dongjak Tax Office notified the head of Dongjak Tax Office of the imposition of corporate tax on the amount equivalent to the interest of this case on April 2014 by deeming that the amount equivalent to the interest of this case belongs to E and the amount equivalent to the interest of this case was invested in H.

C. The director of the distribution tax office, who was the representative director of E, was in de facto closed at the time of issuing B’s bonds with warrants, was not related to the issuance of B’s bonds with warrants, and was another representative director of E in the relevant documents.