A. On June 14, 1995, the Plaintiff established B Co., Ltd. (hereinafter “instant company”) and operated the instant company until now.

B. On the shareholder registry of the instant company, the shareholders listed in the shareholder registry of the instant company are as follows: (a) the Plaintiff (3,000 shares, 30%) C (50%) 5%, D (800 shares, 8%), E (1,000 shares, 10%) 200 shares, G (200 shares, 50 shares, 50%) H (2,000 shares, 200 shares, 20%), I (2,000 shares, 20%) 20% around December 2014.

C. The Defendant: (a) owned 53% of the shares of the instant company by the Plaintiff and its specially related parties (C, D, and E) and owned 100% of the shares issued by the instant company around December 2014 and owned 47% of the shares; (b) accordingly, the Plaintiff is deemed to have acquired 47% of the shares, etc. of the instant company; and (c) on April 12, 2016, the Defendant imposed acquisition tax of KRW 20,350,70, and special rural development tax of KRW 2,035,070, additional tax of KRW 7,018,330, and KRW 30 (hereinafter “instant disposition”) on the Plaintiff (hereinafter “the grounds for recognition”). In the absence of any dispute; (d) entry in the evidence No. 2 and No. 8; and (e) purport of the entire pleadings

2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;

3. Whether the instant disposition is lawful

A. The facts of recognition 1) At the time of the incorporation of the company of this case, there were seven or more promoters for the incorporation of the company of this case (Article 288 of the former Commercial Act (amended by Act No. 5053 of Dec. 29, 1995). The current status of the promoters at the time of incorporation of the company of this case is the above.

1.(b)

As stated in the record, the shareholders are either the plaintiff's father or son's relative (the wife, wife, husband's wife, father's relative, and the plaintiff's employee).

2) The Commercial Act amended on July 24, 2001 and no limitation on the number of promoters for establishing a stock company does not exist. 3) The National Tax Service shall deliberate on application documents submitted by taxpayers, data held by the National Tax Service, and advisory committees, without undergoing a tax investigation, to small and medium enterprises that meet certain requirements in order to support smooth corporate management and family business succession through normal restoration of title trust stocks from June 23, 2014.