A. As the spouse and children of the deceased E (hereinafter “the deceased”), the Plaintiffs reported and paid KRW 22,670,000 of inheritance tax on July 31, 2014 with the taxable amount of inheritance tax as KRW 1,251,071,719, when the deceased died on January 11, 2014.

B. On October 12, 2015, the Defendant conducted an inheritance tax investigation with respect to the Plaintiffs, on the ground that the deceased is the owner of 86,408 shares (hereinafter “F”) in the specification of changes in stocks, etc. of F Co., Ltd. (hereinafter “instant disposition”), and included inherited property of KRW 3,058,583,970 (hereinafter “instant shares”) and the heir was designated as joint and several taxpayers, and decided and notified the Plaintiffs on January 12, 2015 (including additional taxes) of the inheritance tax of KRW 1,498,99,430 (hereinafter “instant disposition”).

C. The Plaintiffs appealed and filed an appeal with the Tax Tribunal on December 23, 2015, but was dismissed on October 28, 2016.

Inheritance tax (including additional tax) related to the shares in the instant disposition is KRW 1,354,038,380.

[Ground of recognition] Facts without dispute, Gap evidence 1, 3, 4, Eul evidence 1, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s disputed shares are the property that the deceased acquired under title trust from G, not inherited property.

B. 1) On March 2015, G submitted a written reply to the effect that “The deceased is the father’s mother of the H Group I’s spouse, and G is the I’s mother. 2) G submitted to a tax official a confirmation document that the deceased himself/herself is the actual owner of the shares, along with the list of stock acquisition in the name of the deceased, as set out below, and on May 15, 2015, “H Group I’s family members, who acquired the shares issued by F, but did not possess financial evidence at the time of acquisition for more than 30 years, and the deceased’s children also recognized that he/she has ownership by entering into an oral title trust agreement with the deceased.”

E 3 F. F.