1. The Defendant’s imposition of global income tax for the Plaintiff on August 5, 2013, which belonged to the imposition of global income tax for the year 2010, penalty tax in bad faith.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “B”) was established on June 12, 2001, and operated a housing construction business, etc. in Sung-nam-si Ctel 317.

From June 1, 2004 to June 30, 2010, the Plaintiff served as the representative director B.

B. On June 30, 2010, the head of Sung-nam Tax Office discontinued B ex officio after the closure of business. The head of Sung-nam Tax Office deemed that the sum of KRW 1,497,969,924 as well as the recognized interest on the short-term loans for shareholders, executives, employees, and employees as well as KRW 66,854,602, which are included in the balance sheet of the business year 2009, was not recovered by the date of the closure of business and disposed of as bonus to the Plaintiff who is the representative director and notified the Defendant of the taxation data.

C. On February 2012, the head of Sung-nam Tax Office sent a notice of change of income amount under the proviso of Article 192(1) of the Enforcement Decree of the Income Tax Act (hereinafter “instant notice of change of income”) to Gwangju-si, Gwangju-si, 202 (hereinafter “instant house”) which is the Plaintiff’s resident registration address.

The Defendant (the tax office having jurisdiction over the Plaintiff’s domicile at the time was Echeon Tax Office, and thereafter, the New Mine Tax Office, which was affiliated with the Echeon Tax Office, was divided into Gwangju City and Hanam-si, and the name was changed into the name of the “Kcheon-si,” and thus, the head of Echeon District Tax Office and the head of the New Mine District Tax Office, upon notification of taxation, determined and notified the Plaintiff on August 5, 2013 of global income tax amounting to 668,758,510 won (including additional tax amounting to 168,789,533 won) for global income tax for the year 2010.

E. On August 30, 2013, the Plaintiff appealed to the Defendant, but was dismissed on October 14, 2013. On January 13, 2014, the Plaintiff asserted to the Tax Tribunal that “B’s former representative director E should dispose of the bonus to E for KRW 1,471,390,000, which was replaced with a short-term loan, out of the provisional payment and recognized interest accrued at the time of his/her former representative director E being in office.”

(f).