1. The Defendant reverted to the Plaintiff on August 1, 2016, the global income tax of KRW 10,042,450, and the global income tax of KRW 10,042,450 for the year 201.

1. Details of the disposition;

A. The Plaintiff is a copyright holder of “B”, “C”, and “D” novel.

B. The Plaintiff filed a complaint against E, etc. with an investigative agency on the ground that the Plaintiff infringed the Plaintiff’s copyright by putting the said novel file up or downloading it without permission by using the web site or siren program. From June 20, 201 to December 31, 2014, the Plaintiff received a total of KRW 566,033,452 (hereinafter “instant agreement”).

C. On August 1, 2016, the Defendant: (a) deemed that the instant agreement amount that the Plaintiff received from the Defendant’s Plaintiff from the Defendant’s Plaintiff constituted “rewards” under Article 21(1)17 of the Income Tax Act; and (b) determined and notified the global income tax of KRW 10,042,450 as global income tax for the year 201, global income tax of KRW 30,824,910 as global income tax for the year 201, global income tax of KRW 31,896,640 as global income tax for the year 2013, and global income tax of KRW 12,837,430 as global income tax for the year 2014.

(hereinafter “instant disposition”) D.

On August 12, 2016, the Plaintiff appealed to the Tax Tribunal, but was dismissed on December 12, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1, 3, Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion that the agreement in this case was received property and mental compensation from the tortfeasor who infringed the Plaintiff’s copyright, and thus, it does not constitute other income as a honorarium under Article 21(1)17 of the Income Tax Act.

Therefore, the instant disposition that imposed the comprehensive income tax on the premise that the said agreed amount falls under other income under Article 21(1) of the Income Tax Act is unlawful.

(b) The details of the relevant statutes are as shown in the attached statutes.

C. Article 21(1)17 of the Income Tax Act provides honorariums as other income.

Here, the honorarium refers to administrative affairs or provision of services, etc.