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1. The types and number of new shares: 32,395 common shares;

2. Par value of one share: 10,000 won per share;

3. The issue value of new stocks: 216,080 won per share;

4. Method of acquiring new stocks: A new stocks shall be allocated in proportion to the number of stocks held by each shareholder, and the new stocks that the shareholder renounces the right may be publicly offered from another general person or may be underwritten by another general person; and

5. Other procedures necessary to issue new stocks shall be entrusted to the representative director.

On October 27, 2014, B Co., Ltd. (hereinafter “instant company”) decided to issue new shares by holding a board of directors on October 27, 2014.

B. On October 28, 2014, the instant company offered 32,395 shares for capital increase (hereinafter “instant shares”). After the shareholders of the instant company acquired 8,099 shares (hereinafter “instant shares”), the Plaintiff owned 418,600 shares in total of the instant company’s shares through free capital increase and par split around December 2015.

The details of changes in the Plaintiff’s shares are as follows:

The number of days of 14,700 -10,00 - - 10,00 - 470 - 470 - 470 - 2,970 - - 18,600 - October 28, 2014 - 13,479 - May 1, 2015 - par value split 394,822 - 418,600

C. The instant company was listed on the KOSDAQ on December 17, 2015, and the Plaintiff reported and paid KRW 78,910,142 to the Defendant on June 30, 2016 on the premise that the acquisition of the instant shares constitutes subject to taxation under Article 41-3 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”).

On August 29, 2016, the Plaintiff acquired the instant shares with the Plaintiff’s capital regardless of the largest shareholder by means of a third party allocation method, and thus, did not constitute subject to taxation. Therefore, the tax amount to be paid shall be revised to zero won.