A. A. B Co., Ltd. (hereinafter “instant corporation”) was a company that has designed and supplied the clothing of piracy, and the deficit of KRW 14,376,832,196 occurred in 209 as 523,808,708 won in 2010, and the deficit of KRW 14,900,640,904 in total was included in the Corporate Tax Act.

B. On April 30, 201, the instant corporation received 47,425 shares of the instant corporation from Nonparty C, who is a representative director of the Plaintiff (the Plaintiff owned 35.35% shares of the instant corporation), and received 95,000 shares of the instant corporation from Nonparty C, who is a partner of the Plaintiff (the Plaintiff’s 35.35% shares of the instant corporation) (hereinafter “instant shares”) and accounted for the accounting of KRW 2,692,96,506 per share in accordance with the supplementary assessment methods under the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201) by evaluating the amount of KRW 18,96 per share as assets increase profit.

(3) 209 - 2011 net income - 5,275,75,75,756,018-17,320,320,867 13,715,965,403,628,62027,110,687,2333,534,023,23233,023,0233,0233,0233,023,234,233,948,948,305,5874,474,472,562,638,326,39,39, - business income of each business year -523,708,708,708,706,1964,164,208,6306,1964,206,61630,64,2967,6306,65

C. On April 30, 201, the head of Seoul Regional Tax Office determined that C and D donated the instant shares to the instant corporation on April 30, 2011, and that the Plaintiff, a shareholder of the instant corporation, obtained a benefit as provided in Article 41 of the Inheritance and Gift Tax Act, and determined that the Plaintiff’s donated property was calculated as KRW 318,462,950 (C Donation), 637,93,170 (D Donation), respectively, and notified the Defendant thereof.