1. Revocation of the first instance judgment.

2. The Defendant: (a) KRW 100,000,000 for the Plaintiff and its related thereto from January 1, 2016 to January 2018.

1. Basic facts

A. 1) Plaintiffs, C, and D (hereinafter “Plaintiffs, etc.”)

A) A contract between F and F representing the Defendant on August 2014 (hereinafter “the primary contract”) provides that “The Defendant will comprehensively take over all rights and obligations regarding the Defendant’s business from the Defendant” (hereinafter “the primary contract”).

(A) The agreement on the transfer of business (Evidence A 2), agreement (Evidence A 3, hereinafter referred to as “the first agreement”) shall be entered into and entered into as follows:

(1) The purpose of Article 6(6) of the Value-Added Tax Act is to comprehensively transfer the rights and obligations of the Defendant’s business, which the F is the representative director and the actual owner, to the Plaintiff, etc., a contract is entered into as follows. The purpose of this contract is to comprehensively transfer the Defendant’s all rights and obligations concerning the Defendant’s business, which the F is operating, to the Plaintiff, etc., thereby transferring the business under Article 6(6) of the Value-Added Tax Act. Article 3 (Transfer, Transfer, Asset, Liability, and Record Date) of the same Act is to take over the total amount of assets and the total amount of liabilities on the current Defendant’s account book on August 31, 2014. The transfer value shall be the balance obtained by subtracting the total amount of liabilities from the total amount of assets under Article 3, and the fixed amount shall be calculated as the amount after depreciation after 2013.