1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From June 18, 1993, the Plaintiff served as a major shareholder and representative director of a stock company B (hereinafter “B”) who runs a construction business (railroad bridge), etc., and transferred the entire stocks and management rights of B to C on May 26, 2008 (hereinafter “transfer of this case”).

B. The settlement of accounts in the B business year 2007, which was prior to the transfer of the instant case, was included in the sum of KRW 2,539,693,350 (hereinafter “the instant provisional payment”), including the provisional payment of KRW 2,204,00,000 for the Plaintiff and the provisional payment of KRW 335,00,00 for short-term loans, and the provisional payment of KRW 2,539,693,350 for the Plaintiff was replaced with the long-term outstanding amount for the Plaintiff after C assumed office as the representative director B.

C. On August 30, 2010, the director of the Yeongdeungpo District Tax Office conducted a partial investigation of corporate tax on B on August 30, 2010, deeming that the instant provisional payment against the Plaintiff was not recovered by the time of the instant transfer, which is the time when the relationship with the Plaintiff and B was extinguished, and disposed of as bonus and notified the Plaintiff of such taxation data as a bonus and the Defendant.

On June 15, 2012, the Defendant notified the Plaintiff of the rectification of KRW 1,067,243,470 as global income tax for the year 2008.

(hereinafter “instant disposition”) e.

The Plaintiff filed an objection and filed an appeal with the Tax Tribunal on December 5, 2012, but the said claim was dismissed on February 12, 2014.

【Ground of recognition】 The fact that there is no dispute, Gap's 1, 3 through 7, Eul's 1, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The summary of the Plaintiff’s assertion is that the instant provisional payment is a processed asset generated in the course of the constructive payment of shares and merely a formal claim, and thus, cannot be disposed of as bonus on the ground that it did not have been recovered until the special relationship is extinguished

Even if not, the share acquisition agreement is made between the Plaintiff and C that contains the content that “all rights of the company are included in the amount of transfer.”