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

A. On February 1, 2007, the Plaintiff acquired 630,000 shares of 630,00 shares per share (hereinafter “instant shares”) from among forfeited shares (4,697,04 shares per share, 1,594 shares per share, 4,698,640 shares in total) generated in the course of capital increase (the date of the subscription date, January 29, 2007; January 30, 2007; February 1, 2007; hereinafter “instant capital increase”) by allocating them to a third party.

On the other hand, the details of the third party allocation of the above forfeited stocks are as follows.

D E F GH IJ

B. The Defendant, on August 16, 201, deemed that the Plaintiff acquired the shares issued at a lower price than 1,200 won per share, the appraised value under Articles 60 and 63 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”) with respect to the acquisition of the shares of this case, and notified the Plaintiff of the determination of KRW 62,956,560 in total of gift tax (hereinafter “instant provision”), and the Plaintiff paid the gift tax on the same day on the same day.

C. After that, on October 14, 2011, the Defendant corrected the aggregate amount of the gift tax on the Plaintiff as indicated in the following table to KRW 42,768,195, and refunded KRW 20,188,365, which is the difference between KRW 62,956,560, to the Plaintiff.

K L MN (based for recognition), Gap evidence 1, 2, Eul evidence 1, 2, Eul evidence 3-1 through 5, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. In the Plaintiff’s assertion, the Plaintiff’s assertion that gift tax should be imposed on the benefit when the forfeited stocks during the capital increase increase program were allocated at a price lower than the market price.