1. The Defendant’s refusal to rectify KRW 7,558,414,290 as corporate tax for the year 2009 against the Plaintiff on May 16, 2013.

1. Details of the disposition;

A. From 2008, the Plaintiff is an implementer of a business that newly constructs and sells apartment units within 13 and 15 Blus among the ancient city development project districts of 334 members of the Handong-gu, Yongsan-gu, Incheon Metropolitan City meal Service. The Plaintiff calculated the amount of income based on the work progress rate and the sale rate, and reported and paid corporate tax for the year 2009.

B. On March 27, 2011 and 2012, when 501 households out of the apartment sales contract were cancelled due to the buyer’s breach of contract, etc., the Plaintiff filed a request for correction to the Defendant for refund of KRW 7,558,414,290 out of the corporate tax reverted in 2009, deeming that the cancellation of such sales contract constitutes grounds for filing a request for correction under Article 25-2 subparag. 2 of the Enforcement Decree of the Framework Act on National Taxes.

C. On May 16, 2013, the Defendant rejected the Plaintiff’s request for correction on the ground that the difference arises between the amount of income appropriated according to the initial rate of work progress as the contract for sale was cancelled and the amount of income confirmed due to the cancellation of the contract, and that the difference should be reflected in the profit and loss of the business year in which the date of cancellation of the contract for sale belongs.

(D) The part on the remaining 425,940,190 won, excluding the 6,339,339,970 won for reduction or refund and 793,134,130 won, as described in paragraphs (d) and (e) above, shall be referred to as "the instant refusal disposition".

On August 20, 2013, the Plaintiff dissatisfied with the foregoing rejection disposition and filed an appeal with the Tax Tribunal on August 20, 2013, and the Tax Tribunal shall be deemed to have never concluded a sales contract for the cancellation of the sales contract after the business year that begins on or after January 1, 2015. As such, the Plaintiff’s appeal partially accepted the Plaintiff’s appeal on the grounds that it is legitimate to refuse the correction of the tax base and tax amount for the pertinent business year, but to reject the cancellation of the sales contract after the business year that begins on or after January 1, 2012.

2.3.