1. The Defendant’s corporate tax of KRW 3,283,904,550 (including additional tax) for the business year 2012 against the Plaintiff on April 13, 2015.

1. Details of the disposition;

A. The Plaintiff owned a holding company established on July 1, 2001 for the purpose of the Group B’s investment and management consulting, and 65% of the outstanding shares of C Co., Ltd (hereinafter “C”) since 2001, and 35% of the remaining outstanding shares of C were owned by D Co., Ltd. (hereinafter “D”).

B. On March 2012, the Plaintiff received proposals from E Limited Company (E; hereinafter “E”) to acquire C’s urban gas business sector.

On June 1, 2012, the Plaintiff prepared a MOU with E, and E presented a final proposal binding on the Plaintiff on August 1, 2012. The main contents of the MOU and the final proposal were “the Plaintiff shall purchase 35% of D’s shares and become a shareholder of C’s 100% of C’s shares; C issued convertible bonds to a person designated by E; and C shall be divided in personnel, and convertible bonds shall belong to C; financial products and assets for lease shall belong to a corporation established by division; and the Plaintiff shall transfer 100% of the shares of C, a corporation surviving the division, to a person designated by E.”

C. On August 16, 2012, the Plaintiff purchased 35% of C’s shares from D to 66,195,570,000 according to the foregoing MOU and its final proposal. The purchase price was equivalent to 35% of the acquisition price of C’s shares as proposed by E.

Accordingly, the plaintiff became a parent company of C's 100%.

On August 21, 2012, the Plaintiff entered into a share transfer agreement with the F limited liability company (E subsidiaries; hereinafter “F”) designated by E, stating that “C’s lease and investment sector are divided by human division, thereby establishing a corporation established by division,” “F will take over convertible bonds of KRW 40 billion issued by C, and the Plaintiff will transfer 100% of the shares of C, a corporation surviving the division, to F, at KRW 58.3 billion.”

(hereinafter referred to as “transfer of this case”). E.

As stipulated in the transfer agreement of this case, the Plaintiff is the case in which “the amount of convertible bonds of KRW 40 billion to F on September 25, 2012 is below 40 billion.”