1. The part of the disposition imposing a penalty surcharge of KRW 60,000,000, which the Defendant imposed on the Plaintiff on July 17, 2014 exceeds KRW 40,000.

1. Details of the disposition;

A. On May 28, 2008, the Plaintiff’s ASEAN and 200,000,000 won as interest rate of 2% on July 28, 2008, and the due date of reimbursement of 20% on July 28, 2008. On May 30, 2008, the Plaintiff prepared a certificate of borrowing that changed the above due date to December 30, 2008, and received a receipt from C as to KRW 200,00,000 on the same day.

B. On May 28, 2008, B prepared a mortgage agreement with C and the above loan amount of KRW 200,000,000 as secured claim and with respect to each real estate listed in the separate sheet (hereinafter “the instant real estate”), which is KRW 300,000,000, with respect to each real estate listed in the separate sheet, and completed the registration of establishment of a neighboring mortgage with respect to the instant real estate on May 29, 2008.

(hereinafter the above right to collateral security (hereinafter “instant right to collateral security”) C.

On February 18, 2014, the head of the Seoul Regional Tax Office notified the Defendant of the violation of the Real Estate Real Name Act that the instant collateral security was trusted to ASEAN, in violation of Article 3 of the former Act on the Registration of Real Estate under Actual Titleholder’s Name (amended by Act No. 11998, Aug. 6, 2013; hereinafter “Real Estate Real Name Act”).

On March 24, 2014, the Defendant notified the Plaintiff of the imposition of penalty surcharges on the violation of the Real Estate Real Name Act. On April 9, 2014 and May 30, 2014, the Defendant received the Plaintiff’s written opinion and relevant supplementary materials from the Plaintiff.

E. On July 17, 2014, the Defendant examined the foregoing supplementary data, and issued a disposition of imposition of penalty surcharge of KRW 60,000,000 (hereinafter “instant disposition”) based on Articles 3 and 5 of the Real Estate Real Name Act, on the ground that the Plaintiff is found to have violated the said Real Estate Real Name Act, on the following grounds: 60,000,000 won for the calculation basis: 300,000,000 (value of real estate) ¡¿ 20% for 60,000,000 = 5% (the assessed value of real estate: 5,00,000,000) for the imposition rate of KRW 60,00 (the lapse period: more than two years) for the violation of the duty of imposition (hereinafter “instant disposition”).

[Ground of recognition] dispute.