On December 8, 2004, the Plaintiff acquired 3,000 shares issued by the non-party company, who was an employee of the non-party company B (hereinafter “non-party company”). Pursuant to Article 41-3(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “the Inheritance and Gift Tax Act”), from C, who fell under the largest shareholder, etc. of the non-party company, at the time of the acquisition of shares issued by the non-party company as the non-party company.

On December 22, 2005, the non-party company offered new shares with capital increase. The Plaintiff acquired 750 shares that it owns (hereinafter “instant new shares”) in KRW 5,000 per share.

On January 2008, the non-party company held par value 1:10 and increased to 37,500 shares of the plaintiff.

After that, the shares of the non-party company were listed on January 25, 2008 to the KOSDAQ market.

The Busan Regional Tax Office conducted an integrated investigation with respect to the non-party company from August 10, 2008 to September 30, 2009, imposed a gift tax on the Plaintiff on the profits of KRW 385,890,000 based on the listing of the first acquired shares (30,000 shares after the split-off). However, the gift tax was not imposed on the profits accruing from the listing of the new shares for consideration.

On January 25, 2010, the Board of Audit and Inspection issued a request for the taxation of KRW 105,00,000 on the profits from listing the instant new stocks for consideration after auditing the business of the Busan Regional Tax Office, and on July 7, 2010, the Defendant imposed an additional tax of KRW 29,647,80 (including additional tax of KRW 8,647,800) on the Plaintiff as the value of donated property.

(hereinafter “instant disposition”). The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on September 17, 2010, but the Tax Tribunal dismissed the disposition on June 30, 201.

【Ground of recognition” without any dispute, Gap 1, 2, Eul 1, and 2, and the purport of the entire pleading is legitimate. The plaintiff's assertion of the disposition of this case is legitimate.