1. The part of the judgment of the court of first instance regarding global income tax accrued in 2011 shall be revoked.

2. The Defendant’s act on July 3, 2017 to the Plaintiff.

1. Details of the disposition;

A. The Plaintiff worked in a bank from March 8, 1982 and retired on January 22, 2009 (class manager at the time of retirement). The Plaintiff is qualified as a credit analysis agent, a loan examination station, and a credit examination specialist.

B. Around 2011, the Plaintiff provided consulting services on the school relocation project, etc. to Company B and received KRW 314 million (hereinafter “instant amount”).

The Plaintiff reported the instant amount as “business income” as listed below at the time of filing the global income tax return.

Amount of the total income of the year of accrual as necessary expenses for the business income in 201 314,000,000 253,808,49260,191,508 / [mark] (unit: Won)

C. From April 13, 2017 to May 22, 2017, the Defendant requested the Plaintiff to submit relevant evidential documents of the amount appropriated as necessary expenses related to the year 2014, but failed to submit relevant evidential documents. As such, the Defendant made an estimation of income tax by expanding the taxable period to five years from January 1, 2014 to May 2015.

On April 18, 2017, the Plaintiff during the tax investigation period, divided the instant amount into “other income” and filed a revised return by applying 80% necessary expenses. D.

On July 3, 2017, the Defendant: (a) deemed that the instant amount constitutes “business income”; and (b) deemed the Plaintiff’s act constituted fraud or other unlawful acts; and (c) imposed global income tax of KRW 101,112,050 (including penalty tax of KRW 17,64,369 and penalty tax of KRW 29,86,910 for nonperformance of payment) on the Plaintiff for the year 2011.

(hereinafter "Disposition in this case"). 【No dispute exists, Gap evidence 1-1, Eul evidence 2-2, evidence 3-1, 5-1, 6-1, and the purport of the whole pleadings.

2. The reasoning for the court’s explanation on this part is as stated in the “2. Related Act and subordinate statute” written in the three pages of the judgment of the court of first instance, and therefore, Article 8(2) of the Administrative Litigation Act, the Civil Procedure Act.