1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. As the director of the Seocheon District Tax Office (hereinafter “instant company”) did not report corporate tax for the business year 2015, the amount of corporate tax for the instant company’s 2015 business year is KRW 692,434,957, and the amount of corporate tax for the instant company’s 2015 business year is corrected as KRW 165,004,983 (including additional tax). On the other hand, 692,434,957, among the above income amount of KRW 692,434,957, the Plaintiff, who was the representative director of the instant company, was working as the representative director in 2015 (as of January 1, 2015, March 27, 2015), the amount equivalent to the amount of corporate tax for the instant company’s 163,149,058 (the changed amount of corporate tax) (including additional tax) x the amount of income in this case’s 692,434,97587.7

B. Accordingly, on February 1, 2019, the Defendant issued a correction and notification of KRW 44,855,390 (including additional tax) on global income for the year 2015 to the Plaintiff (hereinafter “instant disposition”).

[Reasons for Recognition] Each entry of evidence Nos. 2, 5, 6, 8, and 9, and the purport of the whole pleading

2. Determination on this safety defense

A. The Defendant’s defense of this case asserts that the disposition of this case was unlawful and its revocation was sought. The Defendant asserted that the disposition of this case was unlawful since the Plaintiff did not go through the pre-trial procedure, such as a request for examination or a request for trial, etc. on the disposition of this case, and thus, the lawsuit of this case is unlawful.

(b) Entry in the attached Form of relevant statutes;

C. The main text of Article 55(1) of the Framework Act on National Taxes provides that “Any person whose rights or interests are infringed by this Act or any other disposition under tax-related Acts, which is illegal or unreasonable, or because such disposition is not necessary, may request the cancellation or modification of such disposition, or request the necessary disposition pursuant to this Chapter,” and Article 56(2) provides that “Article 55 shall be applied.”