1. The Defendants are jointly and severally liable to the Plaintiff for KRW 88,00,000 and 5% per annum from September 2, 2014 to October 16, 2015.

1. Basic facts

A. On May 2013, the Director of the Daejeon District Tax Office: (a) rendered a tax disposition by the Commissioner of the Yeongdeungpo District Tax Office; (b) the Director of the Daejeon District Tax Office is the Defendant Company’s filing of a petition for

As a result of the tax investigation conducted on May 21, 2013, the Defendant Company issued a prior notice of gift tax (e.g., tax notice: 5,027, 168, 971 won) to Defendant A on the ground that “The capital reduction that the Defendant Company paid to its shareholders in the course of capital reduction in the year 2009 and 2010 was lower than the market price calculated by the supplementary assessment method,” and that the Defendant A received a prior notice of gift tax assessment (e.g., tax notice: 5,027, 168, 971 won) on May 21, 2013.

Accordingly, on December 17, 2013, the head of Yeongdeungpo District Tax Office having jurisdiction over the domicile of Defendant A issued a disposition imposing gift tax of KRW 5,112,469,262 on Defendant A (hereinafter “instant disposition”).

B. 1) The Defendants entered into a delegation contract with the Plaintiff on January 15, 2014 (hereinafter “instant delegation contract”) to proceed with the procedures for protesting against the instant taxation disposition (hereinafter “instant delegation contract”).

Upon examining the contents of the contract, the scope of delegation of duties is “all duties related to a request for review against the National Tax Service, a request for review against the Board of Audit and Inspection, or a request for trial against the Tax Tribunal” (Article 2), and the amount of remuneration shall be 3% of the amount of tax to be refunded or reduced within the limit of KRW 150 million. Of that, the amount of value-added tax shall not be refunded regardless of the outcome; the Defendants shall bear value-added tax; and the remaining payment period of remuneration except for the start money shall be two weeks from the date on which the competent tax office has actually become final and conclusive to decide to cancel or correct the disposition (Article 5)” (Article 5). The Plaintiff received KRW 11 million from the Defendants pursuant to the delegation contract in this case, and on February 6, 2014.