1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. The reasoning for the court’s explanation concerning this case is as stated in the reasoning of the judgment of the court of first instance, except for the dismissal or addition of part of the judgment of the court of first instance as set forth in the following paragraph (2). Thus, this is cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. The second 2nd 2nd 1st 【No. 5,450” in the 6nd 4th 1st to “5,490” in the 6th 4th 1st 1st 1st.

Pursuant to the third Table, the phrase “7,614,742,00 won” as “7,614,742,00 won” as “7,614,742,060 won.”

Each of the "4,917,127,830 won" of the 4th parallels and 5th parallels shall be "4,917,127,840 won".

The fifth page “17,127,830 won” is deemed to be “19,948,400 won”.

From the 6th Schedule, “96,517” in column 4 of Annex 6 is called “965,517”.

Part 7. The following shall be added to the second sentence:

【6) In the lawsuit claiming revocation of disposition of imposing corporate tax, etc. filed by the National Agricultural Cooperative Federation among the above six financial institutions, the Supreme Court Decision 2012Du16084 Decided August 27, 2015 held that it is legitimate to assess corporate tax on the closing price of the exchange on the date of debt-to-equity swap as the market price of stocks. In this regard, it cannot be deemed that there is a justifiable reason to exempt the additional tax, since it is difficult to view that there is a conflict of opinion due to the intention of interpretation" in relation to the above, it cannot be deemed that there

The following is added to the 15th page of the 10th page. On the other hand, the business year under the Corporate Tax Act is stipulated by the articles of incorporation, etc. of a corporation unless there are special provisions in the law. Thus, even if there may be cases where the amount of unpaid taxes varies in the same business year according to the determined business year, it cannot be deemed unreasonable against the tax equity.

Pursuant to Part 11, the following shall be added to the 2nd of the 11st page. "Isia, at the time of disposal of the shares of this case."