A. B Co., Ltd. (hereinafter “B”) is a company established on February 24, 199 and engaged in maritime passenger and cargo transport business.

B. At the time of filing a corporate tax return for the business year 2007, B submitted to the chief of the competent tax office, “The Plaintiff previously owned B shares 5,000 shares (hereinafter “instant shares”) and was transferred from C on August 2, 2007, and owned B shares 20,000 shares as of the end of 2007.” As of the end of 2007, the Plaintiff submitted a detailed statement of transfer of shares and a detailed statement of change of shares. “At the time of filing a corporate tax return for the business year 2008, the Plaintiff was holding B shares 20,000 shares as of the end of 208.”

C. The director of the Seoul Regional Tax Office: (a) conducted a tax investigation on B, etc. from September 15, 2014 to October 5, 2010 of the same year; (b) deemed that the network D (the verification that the deceased was dead on July 2014; hereinafter “the deceased”) was a title trust with the Plaintiff, and thus, (c) notified the Defendant of the assessment data on gift tax on the Plaintiff pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”); and (d) on December 15, 2014, the Defendant notified the Plaintiff of the determination of KRW 88,168,240 as gift tax on gift on December 31, 2007.

(hereinafter “instant disposition”) D.

The Plaintiff appealed and filed an appeal with the Tax Tribunal on August 19, 2015 on March 13, 2015, but the Tax Tribunal dismissed the appeal on January 7, 2016.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 to 4, the purport of the whole pleadings

2. The instant disposition is made.