1. The Defendant’s global income tax amounting to KRW 40,578,790 (including additional tax) for the Plaintiff on December 4, 2013.

1. Details of the disposition;

A. The Plaintiff’s new construction and sale of the Plaintiff’s building 1) The Plaintiff is a resident having his/her domicile in Northern-gu B, 102 Dong 1302, Busan, and on May 3, 2011, on May 3, 201, the Plaintiff is a 160.5 square meters (hereinafter “instant land”).

2) On July 5, 2011, the Plaintiff purchased the instant land, and completed the registration of ownership transfer on June 27, 201. 2) After which the Plaintiff completed business registration on the Housing Construction and Sales Business under the trade name of “D”, and obtained a building permit to construct a building on the instant land on the same day, and starts the construction of studio-type multi-family housing (total 15 households; hereinafter “the instant studio”) with the fifth floor structure around July 22, 2011, and completed the said construction on December 2, 2011.

After that, on December 29, 2011, the approval for use of the studio of this case was rendered, and the Plaintiff completed the registration of ownership preservation on January 4, 2012.

3) Upon completion of the studio in the instant case, the Plaintiff leased each of the instant studio in the respective households, and on January 6, 2012, E and F (hereinafter “E, etc.”)

(2) The sales contract of this case and the entire studio of this case set the sales amount of KRW 885 million as a lump sum sales contract (hereinafter “instant sales contract”).

(4) On March 2, 2012, E, etc. completed the registration of ownership transfer on the instant studio pursuant to the instant sales contract. At that time, the Plaintiff agreed to succeed to the rights and obligations under the lease agreement concluded with respect to the total 15 households of the instant studio, and paid only the remainder after deducting the lease deposit of the said lessee from the purchase price of KRW 885 million.

B. The Plaintiff’s filing of global income tax return for the year 2012 and the Defendant’s filing of the Defendant’s corrective disposition on May 23, 2013, deeming that the Plaintiff’s filing of the global income tax on May 23, 2012 constituted “where the amount of income cannot be calculated based on the relevant account books or evidentiary documents as there is no account books and evidentiary documents necessary for calculating the tax base.”