1. The Defendant’s imposition of KRW 188,90,010 of corporate tax for the business year 2012 against the Plaintiff on January 28, 2014, which was 117,463.

1. Details of the disposition;

A. The Plaintiff was established by three persons, including B and C, and D, around October 2011 (the representative: B); and the Plaintiff is a corporation operating a private teaching institute, such as a lecture for comparison with the Sclst Test and SAT’s College Ability Test (SAT) of the United States.

B. From November 29, 2013 to January 7, 2014, the Defendant conducted a tax investigation with the Plaintiff. During that process, the Defendant investigated the internal computerized account stored in the Plaintiff’s computer and notified the Plaintiff of KRW 838 million (hereinafter “instant account”) of the aggregate of the omitted tuition fees paid in cash or received by the Plaintiff’s shareholder and director, not the Plaintiff’s corporate account (hereinafter “instant account”) in the calculation of the income amount of KRW 137 million for the business year 2012,00,000,000,000 (hereinafter “instant income amount”) and KRW 157 million for the business year 20,000,000,000 for the necessary expenses corresponding to the instant income amount, and confirmed the necessary expenses subject to non-deductible expense amount of KRW 24 million for the business year 20,000,000,000 for the business year 201,2132,1362.

(hereinafter “instant disposition”). C.

On April 22, 2014, the Plaintiff filed an objection with respect to the deductible expenses corresponding to the amount of income of the instant case, among the initial dispositions, on May 21, 2014, the Defendant re-audited on May 21, 2014, and the Plaintiff recognized the Plaintiff’s tuition fees of KRW 27,200,00 (E part 11,200,000, F part 16,000,000) paid as a check in the business year 2012 as deductible expenses, and corrected the Plaintiff’s corporate tax of KRW 196,403,120,000 on August 13, 2014 by reducing the amount of KRW 18,90,010.

(2) Of the initial disposition of this case, the disposition of imposition of corporate tax for the business year 201 and the disposition of imposition of corporate tax for the business year 2012 remaining after the reduction is referred to as “instant disposition”).

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on November 14, 2014, but was dismissed on December 23, 2015.

[Ground of Recognition] Unsured Facts, Gap evidence No. 1, and Eul No. 1.