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

A. B (hereinafter “instant corporation”) appears to have claimed on June 30, 2016 the cessation date of business of the instant corporation based on the details stated in the evidence No. 15 (Notice of Decision of Tax Tribunal) No. 15 (No. 15), but in light of the fact that the evidence No. 15 (No. 15) was written on September 30, 2016 as the cessation date of business of the instant corporation on June 11, 2009, the purpose of which is management consulting business, financial service business, etc. (no. 50,000,000 won (no. 10,000,000 won) of the issued stocks), the Plaintiff and the Defendant, on September 30, 2016, were written on September 30, 2016 as the cessation date.

On March 27, 2013, a non-listed corporation issued 90,000 shares for capital increase (5,000 shares per share) and allocated 15,000 shares to C, a sole shareholder, and 25,000 shares per person to three persons, including the Plaintiff, who is not a shareholder, respectively.

B. From April 25, 2016 to August 23, 2016, the director of the Central District Tax Office: (a) conducted an investigation of changes in stocks with respect to the instant corporation; and (b) on March 27, 2013, the transaction that the Plaintiff acquired 25,000 shares (hereinafter referred to as “instant shares”) directly from 5,00 won per share by means of new shares allotment to a third party on March 27, 2013 falls under the gift income provided for in subparagraph 1 (c) of Article 39 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11845, May 28, 2013; hereinafter referred to as the “former Inheritance Tax and Gift Tax Act”); (c) the transaction that the Plaintiff acquired 25,000 won shares by means of new shares allotment to a third party; and (d) the net value of 300 won shares x 1000 won shares shares x 250140 shares per share (hereinafter referred to as net asset value).