A. From November 1, 2009 to March 31, 201, the Plaintiff served as the president of a stock company B (hereinafter “instant company”) that engages in manufacturing business, such as automobile engines, and the representative director of the instant company is C.

B. On July 29, 2010, the Plaintiff entered into a share acquisition agreement (hereinafter “the share acquisition agreement part related to the instant shares”) with 6 shareholders, 314,000 shares of the instant company (including D, E, F, and G shares 281,961 shares of the instant company’s name) to determine KRW 500 per share as KRW 500 per share, and to acquire KRW 157,000 per share (hereinafter “the share acquisition agreement part related to the instant shares”). On July 29, 2010, the instant company listed the Plaintiff as a shareholder holding KRW 314,00 shares of the instant company.

17,3335,66,500 2 E on June 29, 2010, 201 D 1 D on June 29, 2010, "63,082 31,541,00 G G on June 29, 2010 " 63,082 31,541,000 on June 29, 2010 6,170 3,085,005 H on January 10, 2005 H on June 3, 2010: < Amended by Act No. 10373, Jun. 29, 2010; Act No. 10373, Apr. 3, 2005; Act No. 88213, Jan. 10, 200; Act No. 88213, Feb. 13, 2082; Act No. 6874, Oct. 4, 20107, 407

C. As a result of an investigation of changes in stocks with respect to the instant company from July 29, 2015 to August 27, 2015, the director of the Central Tax Office confirms that C, the representative director of the instant company, has held title trust with D, E, F, and G (hereinafter “title trustee”) the instant shares, and applied the method of assessment of the instant shares to the Plaintiff, calculated as a supplementary method under the former Inheritance Tax and Gift Tax Act (Amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”) pursuant to Article 35(2) of the former Inheritance Tax and Gift Tax Act (Amended by Presidential Decree No. 26960, Feb. 5, 2016; hereinafter “former Enforcement Decree of the Inheritance Tax Act”) and Article 26 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act, deeming that the Plaintiff acquired the instant shares at low price from C, other than a specially related person, without justifiable cause, at the market price of the instant shares.