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

A. On January 27, 2012, the Plaintiff submitted to the head of Samsung District Tax Office a return of inheritance tax base and an order for direct payment of inheritance tax on July 25, 2012, upon the death of the father B (hereinafter “the inheritee”).

B. Upon conducting a tax investigation from March 18, 2013 to June 21, 2013 in order to determine the tax base and amount of inheritance tax of the property inherited from the decedent, the head of Samsung District Tax Office determined that the Plaintiff’s act of offering collateral to the decedent constitutes donation of other profits under Article 42 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201; hereinafter “Inheritance Tax Act”) by analogy Article 41-4(1)2 of the Inheritance Tax and Gift Tax Act on the calculation of donation profits from low interest rates of money, the Plaintiff calculated the amount calculated by subtracting the amount calculated by multiplying the amount of the loan received by the Plaintiff by the adequate interest rate, and the amount calculated by subtracting the amount of interest actually paid by the Plaintiff from the amount calculated by subtracting the amount of interest actually paid by the Plaintiff from the amount calculated by multiplying the amount of the loan by the appropriate interest rate, the Plaintiff imposed the gift tax in accordance with the pertinent tax year and Article 1394 and Article 59 of the gift Tax Act.

(hereinafter referred to as “instant disposition”). C.

On September 2, 2013, the Plaintiff paid a total of KRW 59,950,440, including inheritance tax imposed as above.

The Supreme Court decided on November 14, 2013 (201du18458) that Gap received a loan from the bank after being provided as security for a term deposit claim from his father, while the tax authority has received the benefit of the amount equivalent to the interest in fact. In the judgment of the case where the gift tax was imposed on Gap, the value of donated property due to the provision of security is in principle in accordance with the provisions of Article 42 (1) 2 of the Inheritance and Gift Tax Act and Article 31-9 (2) 1 of the Enforcement Decree of the Inheritance and Gift Tax Act.