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

Cheong-gu Office

The Defendant’s imposition of KRW 00,000,000 on the Plaintiff on April 8, 2013 and KRW 0,000,00,000 on the gift tax of 209 and the gift tax of KRW 0,00,00,00 on the Plaintiff shall be revoked.

(a) An act of avoidance from taxation by thisCC;

1) Done Star Co., Ltd. (hereinafter referred to as "Done") owns a building on the land and its 00-00,000-00, and the third underground floor above the ground and the 10th floor above the ground (hereinafter referred to as "the real estate in this case, combined with land and buildings") and carries on real estate leasing business. ThisCC served as the representative director of Done Star until October 12, 201, and as at the time of 2008, 000 shares issued by Done Star (0.0%) among Done Star's shares as at the time of 200,000 shares (0.0%) held by thisCC and the remaining 0,000 shares (0.0%) held by Kim E, a wife of thisCC, respectively.

2) On May 2008, thisCC: (a) anticipated that the gift of the instant real estate to its children would be subject to a tax of approximately KRW 00 billion; and (b) demanded the FF to prepare a plan for tax reduction. The FF, along with the certified public accountants, planned a plan to donate the instant real estate to its children without paying taxes (hereinafter referred to as “commercial franchise”); and (c) decided to accept it and implement this plan; (d) the details of the franchise are as follows.

In the Republic of Korea, when the gift tax base exceeds 3 billion won, 50% of the excess portion is to be paid, but Hong Kong does not impose income tax or gift tax on stock transfer. Using the fact that Done Star obtained a loan of 00 billion won from the bank as collateral of the instant real estate from the bank and made an investment in China Steel companies through Hong Kong, it would have been pretended that Done Star would have made an investment in the instant real estate after several months, and as such, as if it would have incurred investment losses after the several months, collected 0 billion won out of the said funds as liquidation amount, and the remaining amount is established by establishing a foreign corporation that is a Pacomer in Hong Kong, and changed Done Star to a foreign-capital invested company by acquiring 1/2 or more of the stocks of Done Star to be invested in Done Star through the corporation, and then donated the remainder of Done Star's stocks to its children in Korea without taxes from Hong Kong where no gift tax is levied on the said foreign corporation.

3) On September 12, 2008, thisCC set the FF a sum of KRW 0 billion equivalent to 10% of the appraisal value of the instant real estate in return for the implementation of the Homan Scul in Seocho, 2008. On September 12, 2008, thisCC paid to the FF a sum of KRW 000 million in the amount of money in Hong Kong as the expenses and fees for the establishment of the Sculer in Hong Kong.

B. The flow of money that thisCC has borrowed as collateral the real estate of this case (attached Form 3)

1) Details of thisCC’s transfer of KRW 00 billion

On October 21, 2008, "Done received a loan of KRW 00 billion from the SSS bank as security, and then made a false statement as if it made an investment in Sdaaaaaaa Ibbbbbbbcccccccccccccc (hereinafter referred to as "GIL") a Chinese steel company through the Hong Kong corporation, and then remitted the above KRW 00 billion to the Hong Kong sub-bank (hereinafter referred to as "WTOBC") account in the name of GIL."

00 billion won transferred to the HSBC account in the name of the GIL, ① on October 23, 2008, in the name of the WTOBC Account in the name of the Bank, WhhccC (hereinafter referred to as the “WL”) located in the name of the UK, and ② on the same day, approximately 00 billion won was transferred to the HSBC account in the name of the BGCCcccccccccccccccccccccc (hereinafter referred to as the “BWL”), and approximately 00 won was transferred to the domestic account in the name of the Fund in the name of the UBS BGBC (hereinafter referred to as the “UP”) in the name of the Fund, which is a 00 billion won, to the domestic account in the name of the Fund BGBS 30 billion won in the name of the Bank, and approximately 00 billion won was transferred to the domestic account in the name of the Bank PcccccCq (hereinafter referred to as the “FCB”).

3) The portion used as the increase in capital and the proceeds from the sale of shares of Done Star

D Star newly issued 00,000 common shares of KRW 500,000 per share as an underwriter on November 4, 2008, which was established for Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's 00,000 capital and approximately KRW 00 billion of the acquisition price were paid as 0.0 billion in the foreign capital account of the above Sone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's Lone Star's 10,000 won and KRW 000,0000 (300,000,300,000).

4) Part of the money paid to the FF in compensation for the implementation of franchises

on October 23, 2008, the FF deposited approximately KRW 0 billion in the account of CBDL through various accounts under the name of CBDL III and remitted KRW 00. billion to the Plaintiff, respectively. The above money was fully paid to CBD Korea Co., Ltd. (hereinafter “CBD Korea”) and JJFBD Korea Co., Ltd. (hereinafter “JPV”), and the detailed process is as set out below (hereinafter “CBD Korea”).

5) Sale, etc. of the GIL stocks of thisCC

On June 19, 2009, thisCC would have sold the GIL’s stocks (investment securities) owned by DIL as direct investment in Mauritius to uuuu in Mauritius. The difference between the investment amount of KRW 00,000,000 (which was remitted to the HSBC account in the name of the GIL) and the investment amount of KRW 00,000,000,000 (which was remitted to the HSBC account in the name of the GIL, excluding the commission) was calculated as the investment securities disposal loss, and then reported the corporate tax base for the business year of 2008,000,000.

(c) Results of the discovery of franchises and the investigation, investigation, and tax investigation;

1) On January 2010, K Customs office started an investigation by recognizing franchises.

2) From October 5, 2010 to November 18, 2010, the Director of the Regional Tax Office of Korea conducted a tax investigation on Done Star. As a result, the entire amount of funds leaked as a direct overseas investment is considered to be false investment, and thus, he/she issued a revised and notified the corporate tax for the business year 2010 and the corporate tax for the business year 2011 to Done Star on January 16, 2012, and notified the change in the amount of income as bonus to CC, the representative director, as to the amount including investment securities disposal losses.

3) On January 20, 2012, the prosecutor, who received the case from the KK Customs, filed a public prosecution against thisCC on the grounds of embezzlement of Done Star's funds and suspicion of evading corporate tax, etc. On August 10, 2012, thisCC was sentenced to the above crime of violation of the Act on the Aggravated Punishment, etc. of Specific Economic Crimes (Embezzlement), violation of the Act on the Regulation and Punishment of Criminal Proceeds Concealment, violation of the Act on the Regulation and Punishment of Punishment of Criminal Proceeds Concealment, violation of the Foreign Exchange Transactions Act, violation of the Foreign Exchange Transactions Act, three years of imprisonment and five years of suspended sentence (KV District Court 2012Gohap00,000), and the above judgment was dismissed both the appeal and the appeal of thisCC (KV District Court 2012No000, Supreme Court 2012Do00). The judgment became final and conclusive on April 11, 2013 (hereinafter referred to as "criminal judgment related to the final judgment").

4) Since then, the Defendant applied Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201) to the Plaintiff on April 8, 2013, 2013, on the ground that “NF paid some of the money in the name of the Plaintiff for the purpose of tax avoidance as KRW 0,000,000,000,000,000,000,000,000,000,000,00,000,00,000,00,000,000,00,000,00,000,00,000,000,000,00,000,000,000,000,000,000,000 (hereinafter “instant disposition”).

5) The Plaintiff was dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on June 7, 2013, but was dismissed on November 24, 2014.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 4, Eul evidence Nos. 1 through 5, 18 (including paper numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

Since a large amount of money equivalent to KRW 00 billion is virtually impossible to re-enter the Republic of Korea from DIL, WL, CBDL, and QI III within 24 hours, it cannot be deemed that UF paid the capital of CBDL Korea and JPV to UF, it is difficult to deem that CBDV paid the UF to UF as the consideration for the implementation of LBD franchise. WL and CBDL cannot be deemed as a UF company. The Plaintiff actually performed the JJS development project by submitting a confirmation document to the lender and the Si Corporation at the time of sale of JBS development project, and the Plaintiff acquired the shares from RF Korea under the premise that the Plaintiff acquired the shares under the name of the PBD Korea and the Plaintiff was illegal, taking into account the fact that the Plaintiff acquired the shares under the name of the Malaysia from RF as the financial advisory fee from RI III, the Plaintiff received the funds from RF III, and the Plaintiff was the Plaintiff’s de facto possession of the shares under the name of the PJL and the Plaintiff.

B. Relevant statutes

/ former Inheritance Tax and Gift Tax Act (Amended by Act No. 11130, Dec. 31, 201)

Article 45-2 (Presumption of Donation of Title Trust Property)

(1) Where the actual owner or the nominal owner of any property (excluding land and buildings; hereafter the same shall apply in this Article) required to be registered, etc. for the transfer or exercise of rights is different, the value of such property shall be deemed donated to the actual owner by the nominal owner on the date when it is registered, etc. to the nominal owner (where such property is subject to the change of ownership, referring to the date following the end of the year following the year in which the date of acquisition of ownership falls), notwithstanding Article 14 of the Framework Act on National Taxes:

1. Where he/she registers his/her property in another person's name without any purpose of tax evasion, or fails to change the title in the name of the actual owner who acquired the ownership;

2. Where the name of the actual owner is converted to the period not later than December 31, 1998 (hereafter in this Article, referred to as the "period of grace") with respect to the stocks, etc. on which a record has been made in the register of stockholders or the register of members or a transfer of holders has been made in the name of another person pursuant to a trust or an agreement before January 1, 1997 from among the stocks and equity shares (hereafter in this Article, referred to as the "stocks, etc."): Provided, That the same shall not apply where the name is converted to the name of the person having a special relationship with the stockholders or investors of the corporation which issued the relevant stocks, etc. (hereafter

(2) Where property is registered, etc. under another person's name, or a change of ownership is not made under the name of the actual owner, or where the title of stocks, etc. is not converted under the name of the actual owner during the grace period, it shall be presumed that there exists a purpose of tax evasion: Provided, That this shall not apply where the transferor files a report on the change of ownership along with a tax base return on capital gains under Articles 105 and 110

(c) Fact of recognition;

1) In the course of the K customs and the prosecution’s investigation, thisCC, the FF, the OG, and H were stated as follows:

Classification

Date of Statement

Number of vehicles

Statement Body

Contents of Statement

The Sibuin

Summary

CC

January 27, 2010

10

K Customs Office

Denial

Preparation of a written statement of suspected suspicion at home at the time of search and seizure;

February 9, 2010

20

K Customs Office

Denial

Preparation of a Statement of Actual Loss in Investment

April 21, 2010

3j.

K Customs Office

Sier

F. F. F. D. false overseas investment under the F. F. F.D.’s tax evasion scheme

FF

February 10, 2010

10

K Customs Office

Denial

Preparation of a written statement of suspected suspicion at home at the time of search and seizure;

February 23, 2010

20

K Customs Office

Sier

The primary statement is false and voluntary submission of documents related to the establishment of Pestacom.

March 15, 2010

3j.

K Customs Office

Sier

Confessions made false investments;

April 12, 2010

400

K Customs Office

Sier

Confessions made false investments;

November 12, 2010

500

KVV-mors

Denial

The contents of the existing statement shall be returned;

January 25, 2011

600

KVV-mors

Denial

Maintenance of Contents of the 5th reversal

OG

January 27, 2010

10

K Customs Office

Denial

Preparation of Written Evidence of Suspicion

February 9, 2010

20

K Customs Office

Denial

The same content as the first statement;

February 11, 2010

3j.

K Customs Office

Sier

We reverse the existing statement and cancel the false investment time

February 16, 2010

4.5 5

K Customs Office

Sier

〃 4

March 19, 2010

600

K Customs Office

Sier

The replacement of the suspected facts

August 16, 2010

7 Tears

KVV-mors

Sier

Who is suspected of being suspected

August 25, 2010

800

KVV-mors

Sier

The re-recording of suspected suspicions (video recording);

H H

March 25, 2010

10

K Customs Office

Sier

overseas false investment in accordance with FF instructions

August 17, 2010

20

KVV-mors

Sier

has been engaged in tax evasion by means of false investment

September 3, 2010

3j.

KVV-mors

Sier

〃 4

2) 추IIII 명의의 OO은행 개인MMDA 비거주자 자유원계정(0000-000-000000)에서 0억 원이 2009. 10. 8. 출금되어 원고 명의로 대만에 개설된 PPPPPPP은행 계좌(0000-000-000000)로 이체되었는바(위 00억 원 자금흐름도 상 ⑥ → ⑦ 단계), 당시 당발송금 계좌상세 내역에 의하면 송금인 전화번호는 유FF의 휴대전화인 000-0000-0000로 기재되어 있었고, 송금인 주소 역시 유FF의 주소인 E-0000 QQQQQ2(1)-dong LLLLLLL-gu KKKKK Korea(KK LL구 QQ2동 RRRRR E-0000)로 기재되어 있었다.

또한, 추IIII 명의의 OO은행 정기예금비거주자자유원계정(0000-000-000000)에서 00억 원이 2010. 1. 8. 해지되고, 추IIII 명의의 OO은행 정기예금계정(0000-000-000000)에서 0억 원 및 이자 상당액이 인출된 후, 같은 날 이 중 00.0억 원은 싱가포르 소재 UUU 인베스트먼트 명의의 SS은행 싱가포르지점 계좌(000 000 000000)로 송금되었고, 나머지 00억 원은 추IIII 명의의 OO은행 대외계정(0000-000-000000)으로 송금되었으며, 위 추IIII 명의의 OO은행 대외계정(0000-000-000000)에서 원고 명의의 OO은행 계좌(0000-000-000000)로 다시 00억 원이 송금되었다(위 00억 원 자금흐름도 상 ④ → ⑤ → ⑥ → ⑦단계). 위 과정에서 UUU 인베스트먼트 명의의 SS은행 싱가포르 지점 계좌(000 000 000000)로 00.0억원이 송금될 당시 작성된 지급신청서 및 당발송금 계좌 상세 내역에 의하면 송금인 전화번호는 유FF의 휴대전화인 000-0000-0000로 기재되어 있고, 송금인 주소 역시 유FF의 주소인 E-0000 QQQQQ2(1)-dong LLLLLLL-gu KKKKK Korea(KK LL구 QQ2동 RRRRR E-0000) 기재되어 있었다.

3) Meanwhile, on October 27, 2008, the FF drafted an application for the transaction of an Obank under the name of the World Trade Organization III on October 27, 2008, stating its address, and signed the said application.

4) The representative director, the founder, etc. of companies related to UF franchises are as follows:

Representative Director;

Establishment

An offender;

Date of establishment

State of Location

Capital

(U.S.)

Stockholders

Jinay

GIL

Cartia

International

208.

3. 18.

Hong Kong

3,000,000

Cwww

International,

DDone

a disguised company

uuuu

VIIII

Mauritius

Name Lending Company

Cwww

International

Biwin Ltd

FF

205.

8.23.

BVI

50,000

CC

a disguised company

DIL

VIIII

FF

208.

3. 17.

Hong Kong

100,000

BWL

a disguised company

SI

Sponsoria

FF

208.

3. 17.

Hong Kong

50,000

FCBL

a disguised company

BWL

VIIII

FF

208.

8.8.

BVI

50,000

CC

a disguised company

FCBL

Wxxxx

Business Starter Bus

FF

208.

2.1.

BVI

50,000

CC

a disguised company

Wxxxx

Business Starter Bus

FF

FF

206.

11. 16.

BVI

50,000

FF

a disguised company

CBDL

FF

FF

207.

12. 0. 10

BVI

50,000

FF*

a disguised company

WL

VIIII

FF

203. 203

7. 31.

BVI

50,000

VIIII

a disguised company

* According to the establishment authorization certificate issued by the Financial Services Commission (Evidence No. 36), it is confirmed that the founder of CBDL is the FF. On the other hand, while submitting the evidence No. 17, the Plaintiff asserted that the FF is not the representative and shareholder of CBDL, but the evidence No. 17 is merely a notarial document prepared by an individual notary public located in Hong Kong and thus less credibility than the evidence No. 36. In addition, in the relevant criminal judgment related to the relevant criminal case, the FF was revealed that the CWL’s shareholders and the shareholders of CWL were prepared ex post by thisCC to escape from the suspicion of the domestic investigation agency and to escape from the suspicion of the domestic investigation agency, and in light of these circumstances, it is doubtful that the credibility of evidence No. 17 was raised.

5) On April 12, 2010, the FF stated to K Customs Investigator the following contents:

On October 22, 2008, as ○ Done makes an investment in a foreign country, approximately KRW 00 billion was remitted to the company GIL financial account in Hong Kong’s document.

On October 23, 2008, 2008, the amount of KRW 00 billion remitted by ○ Done to GIL was transferred to the Hong Kong HSBC account in the name of Dozercom.

○ The company that establishes Pucom at the request of the UF would create a Pucom in the name of the World Trade Commission III.

On October 23, 2008, KRW 00 billion remitted to WL is divided into three accounts again, and KRW 14 billion was transferred to CBC account, and KRW 14 billion was transferred to BWL HSBC account, and KRW 0 billion was transferred to FCBC account.

○ On October 23, 2008, approximately KRW 0 billion remitted to CBDL was transferred to the external account under the name of CBD III in Korea.

It is reasonable that the UF sent KRW 100 million to the Plaintiff. It is well known whether the UF sent KRW 00 million to the Plaintiff again has been deposited as shares payment of CBDL Korea.

○○ The FF borrowed the money of the president of thisCC, which was deposited in the name of the State IIII, and the FF was required in connection with the project in charge of the FF, and he remitted the amount of KRW 00 million among them to the large-scale account opened on October 8, 2009 by a large-scale employee who managed the Plaintiff’s assets.

○○ UF made a report to the Plaintiff that the Plaintiff would have to lend funds necessary to establish a corporation under the name of the Plaintiff and treat the Plaintiff, and that it should be repaid later.

On January 2010, the UF stated that the Plaintiff has paid the borrowed money in relation to the business so far to the Plaintiff. After obtaining the Plaintiff’s approval, the FF instructed the employee in charge of CBDL Korea to withdraw the money from the Plaintiff’s account and transfer the money to the personal account of CC.

6) ThisCC submitted to an investigative agency a written statement containing the following:

January 5, 2012

On February 25, 2010, the Plaintiff received KRW 000,000,000 from the Plaintiff’s personal account to thisCC’s personal account on April 9, 2010 (the Plaintiff received KRW 0,000,000,000 from thisCC’s personal account under the Plaintiff’s name (the Plaintiff received KRW 13,00,000 from CBD Korea on February 25, 2010 and paid KRW 0 billion to thisCC as it is, according to the SBD Korea’s account (Evidence 13).

○○ UF confirmed bank records on June 1, 2010 by customs office, so even if the case is forwarded to the prosecution, it was demanded not to investigate the bank records again, and it again transferred KRW 0,000,000,000 to the Plaintiff’s account via the instant personal account from Done Star account.

October 23, 2012

In the past, when the FF viewed the real estate appraisal value as his past experience, the amount of 10% of the real estate appraisal value was paid as a fee. At the time, since the amount of the real estate appraisal in this case was about 00 billion won, thisCC was anticipated to pay approximately KRW 0 billion as a fee.

From September 12, 2008, the FF demanded payment of fees, and thisCC paid 0 billion US dollars (100,000,000 US dollars) as a starting fee and additionally paid 0 billion US dollars (10,000,000 US dollars) in addition, around September 12, 2008.

7) Meanwhile, CBDL Korea was established for real estate development projects on October 13, 2009, and the Plaintiff was holding 100% of the shares, and transferred all shares on April 28, 2010 to FF, and the demotion, the spouse of FF, was the representative director from April 15, 2010.

8) The FF is still missing and is still suspended from prosecution until now.

9) On August 25, 2016, after the filing of the instant lawsuit, the Plaintiff submitted a financial advisory contract (Evidence A No. 49) by asserting that the Plaintiff entered into a financial advisory contract with the Plaintiff on August 25, 2016, and that the Plaintiff would be paid USD 0 million under the said contract, and submitted a letter of commitment (Evidence A 58) to the effect that the Plaintiff was unable to pay the acquisition price of the CBDL stocks of the UNF preparation on October 13, 2016.

10) In the course of the investigation into thisCC, it was revealed that it was possible only once a day to transfer money transferred to Korea after going through the transfer of account between four companies in Hong Kong and four Hong Kong.

[Reasons for Recognition] 5, 6, 8, 9, 38 Evidence, Eul evidence 6 through 11, 13 through 17, 20 to 39 Evidence, respectively

D. Determination

Considering the following circumstances that can be seen by comprehensively taking account of the overall purport of the arguments in the facts admitted as above, it is reasonable to view that the FF trusted the Plaintiff with shares of CBDL Korea and JPV, and the Plaintiff’s assertion is without merit.

① Of KRW 00,000,000, which thisCC transferred to the UF for commercial franchise, 00 billion won, was transferred in the order of Done Star ? GIL ? WDL ? QI III ? Plaintiff and UU Scen Investment. However, in the name of RI III, when it was transferred from the Plaintiff’s account to the PPPPPPPPP bank account (00-00-000000) to the Plaintiff’s account (000-000000), the former table was entered in the list when it was transferred from the Plaintiff’s account under the name of RI III, and the Plaintiff should be deemed to have been transferred to the OF bank account under the name of the Plaintiff (00-000-0000-000) at the same time, and the Plaintiff should be deemed to have been entered in the Plaintiff’s mobile account under the name of UUPPF bank (00 billion won) and the actual name and address of the Plaintiff.

② In light of the fact that: (a) three companies (DIL, BWL, and WL) were the representative director of the disguised company established by the FF; (b) and (c) the FF has repeated transfers by freely using several accounts in the name of CI III, it seems that CI lent its name and account to FI.

③ Although the Plaintiff should directly explain to anyone who received KRW 0 billion from the FF for any reason, whether the Plaintiff received KRW 0 billion from the FF, the Plaintiff’s assertion that the amount of KRW 0 billion from the FF could not be transferred through multiple accounts during the time when 24 hours have not yet elapsed since the time when the instant lawsuit was brought, there is doubt as to credibility, and the Plaintiff’s assertion that the Plaintiff is not a company of CBD groundF when submitting documents prepared by a notary public located in Hong Kong. Since the Plaintiff was the representative director of JFV, it is reasonable for the lender or related company to prepare documents containing the Plaintiff’s signature despite the fact that there was documents containing the Plaintiff’s signature. Therefore, the Plaintiff’s assertion that only indirect assertion, such as the Plaintiff’s assertion that the Plaintiff constitutes the actual shareholder of JFV, and that the Plaintiff was paid KRW 0 billion from the JFV on the closing date of pleadings is difficult to easily assert the Plaintiff’s assertion.

④ The time when the Plaintiff was subject to the instant disposition is April 8, 2013, and the Tax Tribunal did not make any assertion at all in the process of the hearing, and even more than three years have passed since the date of the instant disposition, it is difficult to believe that the respective facts stated in the evidence Nos. 49 and 58 were stated in the Evidence Nos. 49 and 58.

In addition, the Plaintiff asserts that there was a monetary amount to be received from RI III while paying the shares of CBDL Korea and JPV, but it is doubtful whether there was an additional monetary amount other than US$0 million, which was paid from RI III on October 18, 2016, as the share price of CBDL Korea and JPV was paid in addition to US$00,000,000,000,000 as the share price of CBL Korea and JPV. In fact, it is doubtful whether there was the above financial advisory fee contract.

⑤ Meanwhile, the FF stated in the investigative agency that it should have lent the money equivalent to the share price of CBDL Korea and JFV to the Plaintiff and that it should be repaid to the Plaintiff. The above statement is completely different from the Plaintiff’s assertion as to the reasons why the money was transferred to the Plaintiff.

6) The Plaintiff’s assertion that the shares were transferred to the FF on the ground that the Plaintiff transferred the shares of the CBDL Korea to FF and did not receive any income deduction because it did not receive any income deduction.

7) A large amount of money equivalent to KRW 00 billion in the course of the investigation against thisCC was found to be able to re-enter the Republic of Korea from DIL, WL, CBDL, and RI III within 24 hours.

8) ThisCC considered the fee for a premium of KRW 0 billion to the UF, and actually paid it. After the investigation by an investigation agency, upon the commencement of an investigation, the UF returned KRW 0,000,000 to thisCC on April 9, 2010, but thisCC again paid the said fee to the UF on June 1, 2010 upon the request of the UF, and without the fee to be paid to the UF, there is no reason to re-payment of the fee refunded from the UF.

In addition, the UF returned 0,000,000 won to thisCC by using the Plaintiff’s account. Examining the details, the Plaintiff received 0 billion won from CBD Korea on February 25, 2010 and April 9, 2010 where UF holds 100% shares from the UF, and paid it to thisCC. However, the Plaintiff asserted that the FF was paid KRW 0 billion according to the transaction relationship with CBDL Korea, as seen above, appears to have no reason to pay the amount to thisCC. This is merely because the FF had lent 10% shares to the Plaintiff. Thus, the Plaintiff’s assertion that the F had been paid 0 billion won according to the transaction relationship with CBDI, and that there was no reason to accept the payment from the CBDL Korea.

9) Even if the Plaintiff is a business entity that actually makes an international investment, if the share price of CBDL Korea and JJPV is paid with money in the name of the FF, it constitutes title trust.

3. Conclusion

Therefore, the plaintiff's claim of this case is dismissed as it is without merit, and it is so decided as per Disposition.