1. On February 1, 2016, the Defendant imposed value-added tax of KRW 189,572,160 on the Plaintiff on February 1, 2016, KRW 36,616,630.

1. Details of the disposition;

A. A Co., Ltd. (hereinafter “A”) is engaged in civil engineering and construction works, etc., and was authorized to obtain the rehabilitation plan approval from the Seoul Central District Court on October 31, 2013.

(2013. 85. hereinafter “instant rehabilitation plan”) b.

The instant rehabilitation plan provides that “The principal and interest rate prior to commencement shall be 79.5% conversion into equity, and 20.5% shall be paid in cash, and the debt to be converted into equity shall be substituted for the repayment of the rehabilitation claim in question on the date when the new shares issued by the debtor take effect.

C. Rehabilitation creditors converted the remaining amount of credit repaid in cash out of the rehabilitation claim A (hereinafter “instant rehabilitation claim”) according to the instant rehabilitation plan into equity swap at the rate of KRW 1,274 per share.

Rehabilitation creditors are entitled to the deduction of bad debt tax on the amount equivalent to the value-added tax, considering that bad debt under the Value-Added Tax Act has occurred for the difference between the book value of the bonds converted into equity and the market value of the stocks issued through the conversion into equity (hereinafter “the difference in this case”).

E. On February 1, 2016, the Defendant: (a) denied the Plaintiff’s input tax deduction corresponding to the portion for which a rehabilitation creditor was entitled to a bad debt tax deduction; and (b) imposed a disposition imposing KRW 189,572,160 on the Plaintiff for imposition of value-added tax 2013.

(2) The disposition of this case shall be hereinafter referred to as "the disposition of this case". The total amount of creditor's total debt-equity swap (79.5%) 891, 718, 663 708, 916, 377,069 9,031, 386 69, 89, 95163, 625,905 D1,117, 320, 608, 869, 878, 86216, 3059, 405, 4059, 405, 469, 405, 205, 406, 405, 405, 946, 1165, 94, 205, 205, 206, 2054, 204, 165, 108, 1614