1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On December 29, 2010, the Plaintiff acquired the Plaintiff’s shares in KRW 2,366,90,193 by evaluating the net asset value and net profit and loss value per share, average of 24,454 shares of C Co., Ltd. (hereinafter “Co. D”) (hereinafter “instant shares”) (hereinafter “instant shares”) from B, as an weighted average value, 96,790 won per share.

B. Around February 2015, the Defendant notified the Plaintiff of the result of the Defendant’s tax investigation that: (a) the Plaintiff constitutes the Plaintiff’s specially related person; and (b) the instant company is in the process of suspending or closing its business operations since it actually discontinued its business operations prior to the transfer of stocks; (c) the Plaintiff notified the Plaintiff that the Plaintiff would impose corporate tax by including its shares in gross income on the ground that it constitutes a case where the Plaintiff purchased securities of KRW 1,639,080,720, which is the difference from a specially related person, at low price, are assessed as KRW 4,005,980 per share of net asset value.

C. On May 12, 2015, the Plaintiff filed a request for pre-assessment review with the Defendant on May 12, 2015, and the Defendant held the first examination of the National Tax Examination Committee on July 23, 2015 (hereinafter “the first examination”).

(2) After the first examination, the Defendant, on July 29, 2015, again held a review of the National Tax Examination Committee on the issue of whether the instant company constitutes a corporation under temporary closure or permanent closure of business (hereinafter “the second examination”) on the grounds that the first examination result was contrary to statutes or the previous statutory interpretation, etc., and re-scheduled the agenda, but the National Tax Examination Committee, upon the second examination, provided that the said agenda was presented an opinion of non-adopted by the majority as to the above agenda.

3. The defendant's decision on July 31, 2015 is based on the results of the second examination in the decision on pre-assessment review.