1. The judgment of the first instance court, including a claim that was modified by this court as follows. A.

The plaintiff.

Basic Facts

on January 23, 2009, F Co., Ltd. F (hereinafter “F”) added gold export business and futures investment business to its intended business, and Co-Defendant D of the first instance trial was appointed as representative director on July 15, 2009.

F purchased gold in the Republic of Korea from February 9, 2009 to June 2010, the F exported gold bullion in the form of Alley to G (G companies, hereinafter “G”) located in Hong Kong.

On the other hand, around November 2009, K Co., Ltd. and around March 2010, L Co., Ltd. (hereinafter referred to as “Stock Co., Ltd.” in its name omitted) opened each gift account, and F made a gift investment in amounting to approximately KRW 5.4 billion in the F’s account from November 2009 to June 2010, through each of the above investment securities certificates.

F In the tax investigation and administrative litigation of F, the F declared corporate tax by appropriating the purchase price of gold in the business year 2009 as KRW 309,830,057,518.

The head of Sung-dong Tax Office shall specify the F's purchase price of high gold in KRW 12,517,530,851 as stated in the fifth summary of the judgment.

In September 6, 2010, F made a disposition to impose corporate tax of KRW 3,826,95,790 on F for the business year 2009.

Accordingly, F filed a lawsuit seeking revocation of the disposition imposing corporate tax as Seoul Administrative Court 2012Guhap2287, but the claim was dismissed on April 19, 2013. The Seoul High Court appealed 2013Nu15981, but the appeal was dismissed on January 21, 2015 and became final and conclusive on February 10, 2015.

(1) The Plaintiff’s criminal complaint related to the gift investment related to the revocation of the disposition of imposition of corporate tax (hereinafter “relevant administrative case”) asserts that Defendant C was the actual operator of F on November 6, 2012, and Defendant C was the actual operator of F, and without the consent of investors, including the Plaintiff, etc., in relation to gold bullion export business from October 10, 209 to June 21, 2010.