1. Revocation of a judgment of the first instance;

2. On January 6, 2015, the Defendant imposed global income tax on the Plaintiff.

1. Details of the disposition;

A. The Plaintiff was in office as the chairman of the B Trade Union composed of the employees of the B Co., Ltd. (hereinafter “instant Trade Union”), and was dismissed from the said company on January 2007.

B. The Plaintiff received from the instant trade union the amount of KRW 475,86,00 in total from January 2007 to May 2012 the status guarantee fund created at the expense of the union members from around January 2007 to around May 2012 (hereinafter referred to as the “instant provision”) to KRW 475,86,00 in terms of living expenses and retirement benefits as reserves (=91,491,00 (2007) + + KRW 86,406,00 (2008) + + KRW 73,675,00 (209) + + KRW 85,909,000 (209) + + KRW 80,275,000 (201) + + KRW 58,110,000 (201), and hereinafter referred to as the “the instant money”).

C. The Defendant, on January 6, 2015, determined and notified that the instant amount that the Plaintiff received as above falls under other income (e.g., the amount reverted to year 2008) of the global income tax of KRW 139,068,060 (the amount reverted to year 2007) plus KRW 29,539,950 (the amount reverted to year 2008) + KRW 20,326,640 (the amount reverted to year 2009) + KRW 22,754,460 (the amount reverted to year 2009) + KRW 19,183,80 (the amount reverted to year 201) + the amount reverted to year 22,754,460 (the amount reverted to year 2010) + KRW 10,438,350 (the amount reverted to year 2012))].

(hereinafter “instant disposition”) D.

On September 21, 2015, the Tax Tribunal dismissed the Plaintiff’s request on September 21, 2015.

[Ground of recognition] Facts without dispute, Gap evidence No. 1, Eul evidence No. 1, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The key issue of the instant case is whether the instant money constitutes an honorarium under Article 21(1)17 of the Income Tax Act.

B. The following facts can be acknowledged in light of the evidence, Gap evidence No. 2, Eul evidence No. 4, and the purport of the whole pleadings.

Article 3 (Purpose) The provisions of this Rule shall be the status of partnership activities specified in Section 2 of Rule 10 (Rights and Guarantee of Status) of the Branch Operation Rules.