1. On July 27, 201, the Defendant imposed corporate tax of KRW 162,528,620 on the Plaintiff for the taxable year 2009.

1. Details of the disposition;

A. The Plaintiff is a juristic person engaged in the manufacturing business of mountain field active agents, etc., and the Plaintiff owns 40/100 of the total number of stocks generated by the deceased and non-listed corporation (hereinafter “satisfic maintenance”).

B. When the Plaintiff filed a corporate tax return for the business year in 2009 (from October 1, 2008 to September 30, 2009), the Plaintiff applied for special tax reduction or exemption for small and medium enterprises under the Restriction of Special Taxation Act, and received corporate tax reduction or exemption for research and human resources development expenses.

C. As of the end of the immediately preceding business year 2008 (from October 1, 2007 to September 30, 2008), the Defendant owned at least 30/100 of the total number of the Plaintiff’s shares generated, and the Plaintiff excluded the application of tax reduction and exemption and deduction provisions related to small and medium enterprises under the Restriction of Special Taxation Act on the ground that the Plaintiff does not constitute a small and medium enterprise subject to the special tax reduction and exemption and research and human resources development tax credit in the business year 2009, and imposed corporate tax on the Plaintiff on July 27, 2011 (including additional tax 23,627,140 won) for the Plaintiff.

(hereinafter “instant disposition”) D.

On September 20, 201, the Plaintiff appealed to the Board of Audit and Inspection on September 20, 201, but was dismissed on April 11, 2013.

[Ground of recognition] Unsatisfy, Gap evidence 1, 2 (including branch numbers if there are branch numbers), Eul evidence 1 to 4, the purport of the whole pleadings

2. The plaintiff's assertion

A. Where a company ceases to be a small or medium enterprise due to the amendment of the attached Table of the Enforcement Decree of the Framework Act on Special Taxation pursuant to Article 2(5) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 19329, Feb. 9, 2006; hereinafter “former Enforcement Decree of the Restriction of Special Taxation Act”), special taxation related to small or medium enterprises shall apply for the business year in which the reason for grace arises and the next three business years until

As of the business year 2005.