1. The Defendant imposed corporate tax of KRW 2,655,519,960 (including additional tax) on the Plaintiff on March 24, 2014 for the business year 2008.

1. Details of the disposition;

A. The Plaintiff (former: B) was listed on the KOSDAQ-listed corporation that runs bicycle manufacturing and sales business, and listed on the KOSDAQ on April 26, 2007.

On July 18, 2008, C Co., Ltd. (hereinafter “C”) which is an unlisted corporation engaging in travel business, etc. are merged (hereinafter “instant merger”) and completed the merger registration on July 22, 2008.

B. The Plaintiff and C calculated on April 20, 2008 pursuant to Article 190-2(1) of the former Securities and Exchange Act (wholly amended by Act No. 8635 of Aug. 3, 2007; hereinafter “former Securities and Exchange Act”); Article 84-7(1) of the former Enforcement Decree of the Securities and Exchange Act (wholly amended by Presidential Decree No. 20947 of Jul. 29, 2008; hereinafter “former Enforcement Decree of the Securities and Exchange Act”); Article 36-12 of the former Enforcement Rule of the Securities and Exchange Act (wholly amended by the Enforcement Rule of the Financial Investment Services and Capital Markets Act, No. 885 of Aug. 4, 2008; hereinafter “former Enforcement Rule of the Securities and Exchange Act”); and on the basis of the appraisal base date of the Plaintiff’s shares issued and issued by the merged corporation, 319,319,319,319,329,319,316, etc. shares issued and shares issued by the merged corporation

The Plaintiff issued 3,292,216 shares of the merger according to the above merger ratio and delivered C’s shares to the shareholders, and the separate merger subsidy was not paid.

C. The Plaintiff issued 8,823,138,880 won (=3,292,216 shares x the closing price of the Plaintiff’s shares exchange x July 18, 2008 583,651,520 won, which is the difference between the fair value of net assets of C and the fair value of net assets of C after the instant merger (hereinafter “working rules on combined accounting”) and 8,239,487,360 won.