1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The establishment of the principal duty to pay taxes by the Songin FFV Co., Ltd. and the status of oligopolistic shareholders prior to the split-off 1) Songin FFV Co., Ltd. (hereinafter “ Songin FV”).

On January 22, 2008, A purchased a total of 12 parcels of land in Pyeongtaek-si B from A, a total of 13 parcels of land in the same Dong from C, and a total of 5 parcels of land in the same Dong from D respectively. 2) Forwarding PFV paid all sales prices to A, C, and D on August 24, 2009, but did not complete the registration of ownership transfer by June 1, 2010, the assessment basis date of comprehensive real estate holding tax for the year 2010.

3) On December 12, 2012, the Defendant: (a) deemed that Songininavivic actually owns a total of 28 parcels of land among each of the lands listed in paragraph (1) as at the tax base date; and (b) designated the due date for payment as at December 31, 2012 and imposed a special rural development tax of KRW 259,329,990 for comprehensive real estate holding tax for 2010 and KRW 51,865,990 for special rural development tax for which it is principal tax.

(hereinafter “PFV’s respective tax liability” (hereinafter “principal tax liability”) and on the other hand, on June 1, 2010, the date when the consignor’s primary tax liability becomes effective, the Daewoo Motor Sales Co., Ltd. (hereinafter “PFV sales prior to division”).

) 80.46% of the shares issued by Songinin-V (hereinafter “instant shares”)

B. (B) The company division and the Plaintiff’s establishment 1) However, on August 10, 201, the Daewoo Motor Sales was decided to commence the rehabilitation procedure (hereinafter “instant rehabilitation procedure”) under the Debtor Rehabilitation and Bankruptcy Act (hereinafter “ Debtor Rehabilitation Act”) by the Seoul Central District Court 2011 Gohap105, under the Debtor Rehabilitation and Bankruptcy Act (hereinafter “Rehabilitation Act”).

2) Under the instant rehabilitation procedure, the rehabilitation plan submitted by the administrator of the treatment Motor Vehicle Sales prior to the split-off on December 9, 201 was approved (hereinafter the above approved rehabilitation plan is referred to as “instant rehabilitation plan”).

3) The instant rehabilitation plan is prior to the division.