1. Acquisition tax of 193,243,220 won (including additional tax of 57,031,740 won) imposed on the Plaintiff on November 9, 2015, and special rural development tax of 16.

1. Details of the disposition;

A. A. A Co., Ltd. (hereinafter “instant company”) conducting food franchise business was established on November 5, 2010.

At the time of the incorporation of the instant company, the total number of issued shares was 10,000 shares (5,000 won per share) but the total number of issued shares increased to 15,000 shares on October 5, 2012.

B. The details of the change in shares of the instant company on the detailed statement of the change in shares are as follows.

CD

C. On August 31, 2013, the Defendant deemed that the Plaintiff acquired 5,00 shares of the instant company from C, and determined and notified the Plaintiff of KRW 193,243,220 (including additional taxes) and KRW 16,60,080 (including additional taxes) based on the tax base calculated by multiplying the Plaintiff’s increase in equity ratio in the instant company by 33.33%, the book value of real estate subject to acquisition tax of the instant company by the book value of 20,433,766,614.

(hereinafter “instant disposition”) D.

On February 5, 2016, the Plaintiff appealed and filed a request with the Tax Tribunal for a tax trial, but was dismissed on June 17, 2016.

[Ground of recognition] A without dispute, Gap evidence Nos. 1 through 3 (including branch numbers for those with additional numbers; hereinafter the same shall apply), Eul evidence Nos. 1 and 3, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff asserted that the Plaintiff owned all of the shares of the instant company since its establishment.

However, at the time of the establishment of the Plaintiff, the Plaintiff: (a) deemed that if the instant company appears as the Plaintiff’s individual company, it would hinder the securing of franchise franchise franchise franchise stores; (b) held the title trust of 5,00 shares of the instant company to C; (c) around September 201, in order to lower the share ratio held in title to C by 50%, the Plaintiff again held the title trust of 500 shares trusted to C with the Plaintiff’s 500 shares and 500 shares trusted to C; (d) around October 2012, the Plaintiff raised the Plaintiff’s share ratio through capital increase with capital increase and recovered the shares trusted to D; and (e) on August 31, 2013, the size of the instant company is too excessive.