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

A. On December 17, 2009, BB Unemployment Co., Ltd. (hereinafter referred to as “BB Unemployment”) accounted for a representative director for a short-term loan of KRW 000,000, and then withdrawn KRW 000 (hereinafter referred to as “the issue amount in this case”) from the SC Bank passbook in the name of BB Unemployment on the same day.

B. On November 4, 2009, the Plaintiff, as the child of Hannun, entered into a lease agreement that leases OE 000 in Gangnam-gu Seoul (OE 000) with KimD and lease deposit as of November 4, 2009, and on December 17, 2009, KRW 000 out of the key amount of this case, was paid as the remainder of the above lease agreement and KRW 000 was paid as brokerage commission.

C. From January 12, 2011 to February 16, 2011, the director of the Seoul Regional Tax Office conducted an integrated investigation into the corporate entrepreneur for BB unemployment in 2008, and confirmed the above facts, and determined that newCC’s key amount of the instant case leased from BB unemployment was donated to the Plaintiff on December 17, 2009, and notified the Defendant as taxation data.

D. Accordingly, on April 28, 201, the Defendant decided and notified the Plaintiff of KRW 000,000, gift tax reverted to the year 2009 following the donation of the key amount of the instant case (hereinafter “instant disposition”).

E. On July 22, 2011, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the said appeal on November 21, 201.

[Based on Recognition] The facts without dispute, Gap evidence 1, Eul evidence 2, Eul evidence 1, 2, 5, and 6, and Eul evidence 1, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

In full view of the following circumstances, the key issue amount in this case is clear that the plaintiff was lent from BB Unemployment, and it cannot be viewed that the plaintiff was donated from NewCC, and the disposition in this case must be revoked.

1) The Plaintiff intended to directly borrow the instant key amount from BB unemployment, and the relationship between BB unemployment and (3) the newCC borrowed the instant key amount from BB unemployment, and then, the Plaintiff took the form of borrowing the key amount from the newCC, and the use of the newCC as a kind of conduit in the financing transaction.

2) On January 27, 2011, the Plaintiff borrowed KRW 000 from FF Development Co., Ltd. (hereinafter “FF Development”), repaid the loan obligation to NewCC, and NewCC repaid the loan obligation to BB unemployment with the said money on January 31, 201, and the instant key amount was ultimately repaid by the Plaintiff.

3) The Plaintiff, who had been living in the workplace since December 198, intended to pay the key amount of the instant case as the lease deposit to be returned at the time of termination of the benefits or the lease contract.

(b) The light related age;

The entries in the attached Table-related statutes are as follows.

C. Determination

1) Facts of recognition

A) The current status of BB Unemployment publishing note is as listed below, while the shares issued by the GG industry conference are 20% of newCC, 20% of newCC’s wife, 30% of the Plaintiff, and ASEAN’s 30% of newCC’s 30%.

B) On January 27, 2011, the Plaintiff entered into a loan agreement with the FF development and repayment period one year from the date of lending to receive a loan of KRW 000,000, and on the same day, received a remittance of KRW 000 to the new bank passbook in the name of the Plaintiff.

C) Around that time, the Plaintiff remitted the said money to NewCC, and NewCC deposited the said KRW 00 on January 31, 201 to the passbook in the name of BB unemployment.

D) Meanwhile, FF Development is a subsidiary of BB Unemployment, which holds 100% of its issued stocks, and net loss in the year 2010 is KRW 000.

[Based on Recognition] The non-contentious facts, Gap evidence 3, Gap evidence 4-1 to 3, Gap evidence 6, Gap evidence 7-1, and Eul evidence 7-2, and the purport of the whole pleadings

2) Determination

In light of the following circumstances acknowledged by the above facts, Gap evidence No. 6, and the purport of the entire arguments, it is reasonable to deem the issue amount of this case was donated to new II, and on different premise, the plaintiff's above assertion is without merit.

A) On December 17, 2009, the Plaintiff did not receive the key amount of the instant case and did not prepare a BB Unemployment or a new II loan certificate with the Plaintiff.

B) If the substance of the issue amount in this case is a loan to the plaintiff in BB unemployment, it is common to pay the interest on a regular basis, and there is no interest paid (the plaintiff asserts that the newCC is a kind of conduit in the transaction of the issue amount in this case, and that the loan transaction between the father and the father is more consistent with the empirical rule with respect to the unpaid interest, but it is not consistent with the plaintiff's assertion.

C) In light of the current status of BB unemployment shares issued, BB unemployment becomes a single company controlled by NewCC, and most of the economic interests of BB unemployment and newCC are consistent.

D) The time when the Plaintiff returned the instant issue amount to NewCC was conducted on January 27, 201 by the Director of the Seoul Regional Tax Office’s integrated investigation into corporate business entities with respect to BB unemployment.

E) In view of the fact that: (a) the Plaintiff transferred KRW 000 from FF development on January 27, 201 to the newCC; (b) deposited the said money in the passbook in the name of BB unemployment again on January 31, 2011; and (c) the BB unemployment holding 100% of the issued FF development stocks is de facto controlling and managing the cash in the name of FF development, it cannot be deemed that the said KRW 000 was deposited into the passbook in the name of BB unemployment; and (b) there was a substantial change in the pride in the circumstances of BB unemployment.

F) It does not seem as a normal monetary transaction to lend KRW 000 to the FF development from the Plaintiff without being offered any security against the Plaintiff’s net loss in 2010.

3. Conclusion

Therefore, the plaintiff's claim of this case is dismissed as it is without merit, and it is so decided as per Disposition.