Of the instant lawsuit, the Defendant imposed global income tax of KRW 238,192,320 on December 3, 2018 on B, 2012.

1. Details of the disposition;

A. On May 20, 2009, the Plaintiff, a corporation established for the purpose of real estate development and sale business, entered into a sales contract with C to purchase KRW 9,852 square meters of forest E in the name of the seller D (C’s father) for KRW 16,463 square meters of forest land in Gwangju City (hereinafter “instant land”) and pay the sales price around that time.

On September 21, 2009, the Plaintiff concluded a sales contract between F and F Co., Ltd. (hereinafter “F”) for selling 6,611 square meters of the instant land in F to KRW 600,00,000, and on June 9, 2010, between F’s auditor G and G, for selling 3,240 square meters of the instant land to G for KRW 343,00,000 (hereinafter “the instant subsequent sales contract”). From September 21, 2009 to June 18, 201, the Plaintiff received both payment from F and G for the total purchase price of KRW 943,00,000,000.

B. However, inasmuch as D had already died before the instant preceding sales contract, due to the conflict of opinions among the successors, C was unable to obtain the power of representation from the remaining successors, and thus failed to perform the obligation to perform the obligation to perform the registration of ownership transfer under the instant preceding sales contract, the Plaintiff cancelled the instant post-sale sales contract between F and G on August 30, 2012, and transferred the ownership of the land H and seven (hereinafter “the instant I land”) to F in Dongducheon-si, Hacheon-si, in lieu of the refund of the purchase price, and agreed that F will acquire the secured debt of the financial institution of KRW 462,00,000 with respect to the instant I land, and accordingly, F completed the registration of ownership transfer as to the instant land on September 21, 2012.

The instant land was owned by the Plaintiff. On June 2, 2010, the Plaintiff was about J Co., Ltd. (hereinafter “J”) and the instant I land.