A. The Plaintiffs acquired shares issued by F Co., Ltd. (hereinafter “instant company”) from C, D, and E (hereinafter “instant company”) for KRW 5,000 per share as indicated below:

(2) The number of shares acquired by the Plaintiff on December 31, 2008 from C shall be 1; the shares acquired on December 31, 2009 shall be 208; the shares acquired on December 30, 2010 from D; the shares acquired on December 30, 2010 by Plaintiff B shall be 3; the shares acquired on December 30, 201 by Plaintiff B shall be 4; and the shares acquired on December 30, 208 shall be 1 to 4; and the shares acquired on December 30, 208, 208, 37, 720 won shall be 10, 36, 308, 208, 204 won per share of the shares acquired on November 30, 2007; and the shares acquired on December 31, 2008, 300, 100, 50, 18, 2008 won shall be 36.

B. 1) As a result of an investigation of stock change with respect to the instant company, the Director of the Central Tax Office of China shall: (a) the Inheritance Tax and Gift Tax Act (hereinafter “Gift Tax Act”).

(2) According to the supplementary assessment method under Article 63, the Plaintiff evaluated the net profit and loss and net asset value per share as of the date of stock transfer in accordance with the weighted average rate of 3 to 2, respectively, as indicated in the table of the market price as of the date of stock transfer, and received shares 1, 2 from an unrelated C at a price significantly lower than the market price, and the Plaintiffs notified the Plaintiffs that they would levy gift tax on November 11, 201 by deeming that they acquired shares 3, and 4 from a related C at a price lower than the market price. (2) The Plaintiffs were dissatisfied with the request for a pre-assessment review to the Deputy Director of the Regional Tax Office, but received a non-adopted decision on January 20, 2012.

C. On the other hand, on December 1, 201, 201, before the decision of non-adopted by the director of the Central District Tax Office, the defendant against the plaintiff A on December 31, 2008, the gift tax of 4,531,670 won and December 31, 2009.