2. The costs of lawsuit are assessed against the plaintiffs.

A. On February 4, 2014, the Defendant: (a) deemed that Plaintiff B, the spouse of Plaintiff B, has held title trust with 669,943 shares of Maciopic Co., Ltd. (hereinafter “instant shares”); and (b) imposed gift tax of KRW 74,362,400 on Plaintiff B, the joint and several tax obligor of Plaintiff A and the joint and several tax obligor.

(hereinafter “instant disposition”). (b)

Plaintiff

B filed an appeal with the Tax Tribunal on March 14, 2014, but was dismissed on June 18, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 3, Eul evidence 2 and 3 (including provisional number; hereinafter the same shall apply), the purport of the whole pleadings

2. The defendant asserts that the lawsuit of the plaintiff A is unlawful on the grounds that the plaintiff A did not go through the procedure of the pre-trial trial, since the plaintiff A did not meet the requirements of the pre-trial trial.

In a tax litigation, the provisions of Articles 18(2) and (3), and 20 of the Administrative Litigation Act are not applicable (Article 56(2) and (3) of the Framework Act on National Taxes), but in the same case, where several persons are to be equally responsible for the same administrative disposition, one of those who are liable for the same administrative disposition may file an administrative litigation seeking revocation of the taxation disposition even if the taxpayer and the Tax Tribunal have given the Commissioner of the National Tax Service and the Tax Tribunal an opportunity to re-determine the basic facts and legal issues by going through legitimate pre-trial procedures.

(see, e.g., Supreme Court Decision 2005Du10170, Apr. 14, 2006). However, in this case, it is problematic whether Plaintiff B donated the instant shares to Plaintiff A, and whether title trust was made.

Plaintiff

B The Tax Tribunal asserted that the instant disposition, which was based on the title trust, was unlawful, because the instant shares were donated to the Plaintiff A in the proceeding of the Tax Tribunal, and the Tax Tribunal could have determined that the instant disposition was unlawful.

Therefore, the same facts have already been reported.