1. The Defendant’s stamp tax of KRW 8,019,708,00,00 as indicated in the attached Table 1 List against the Plaintiff on January 25, 2013.

1. Details of the disposition;

A. The Plaintiff, as a key telecommunications business operator under the Telecommunications Business Act, was designated as a key telecommunications business operator of the IMT 2000 service (hereinafter “instant service”), which is a mobile communications service from the Ministry of Information and Communication around December 2001, as a key telecommunications business operator under the Telecommunications Business Act.

B. The Plaintiff paid KRW 8,019,708,00 of the stamp tax from December 2009 to December 2010 on the application form received when providing the instant service to the customer, as shown in the attached Table 1, and on January 9, 2013, the Plaintiff filed a request for correction to refund the stamp tax that was paid by mistake and mistake even though the application form for subscription to the instant service does not constitute a stamp tax document under the Stamp Tax Act.

C. However, on January 25, 2013, the Defendant rejected an application for rectification on the ground that the application constitutes a taxable document stipulated in the Enforcement Decree of the Stamp Tax Act and the Stamp Tax Act.

(hereinafter referred to as "the disposition of this case") d.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 12, 2013, but the said claim was dismissed on March 4, 2014.

【Ground of recognition】 The fact that there has been no dispute, entry of Gap's 1 through 4, the purport of whole pleadings

2. Whether the instant disposition is lawful

A. (1) The Plaintiff’s assertion (1) The Telecommunications Business Act, the Radio Waves Act, etc. classify the “instant service” as the object of stamp tax documents under the Enforcement Decree of the Stamp Tax Act, and in light of the principle of strict interpretation derived from the principle of strict interpretation, etc., the Plaintiff’s application for the instant service cannot be deemed as a stamp tax document as stipulated in the Enforcement Decree of the Stamp Tax Act and the Stamp Tax Act.

(2) The defendant's assertion under the laws and regulations governing stamp taxes.