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

A. The Plaintiff and the Plaintiff’s father B are shareholders holding 60% and 40% of their respective shares in C Co., Ltd. (hereinafter “instant company”) engaging in real estate development and supply business, etc.

B. B leased money free of charge as described below from January 1, 2011 to December 31, 2014 to the instant company with deficits in each business year of 2011, 2012, and 2014.

(hereinafter referred to as “each of the instant loans” in 2011, 2012 and 2014). [Attachment 1] Business year of gratuitous lending 9,616,50,6839,220,216, 3827,168,064, 6595,03,064,659 (unit :)

C. As a result of the tax investigation of gift tax in 2010-2014 against the Plaintiff from September 1, 2015 to October 10, 2015, the director of the Seoul Regional Tax Office: (a) as to the instant gift to the Plaintiff, the Plaintiff was notified of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; (b) with respect to the 2012 gift, the former Inheritance Tax and Gift Tax Act (amended by Act No. 12168, Jan. 1, 2014; (c) with respect to the 2011 gift, the former Inheritance Tax and Gift Tax Act was amended by Act No. 111130, Dec. 31, 2015; (d) without distinguishing it from the date of convenience, and with respect to the 2014 gift as indicated in the statutes as the basis for the 2014 gift, Article 416(1)65) of the former Enforcement Decree of the Tax Act (amended by Presidential Decree)

[The value of donated property shall be calculated by the formula of “free loan amount 】 The appropriate interest rate of the Ministry of Strategy and Finance notice (9% until November 4, 2010, and thereafter 8.5%) 】 Plaintiff’s share ratio of 60%. In the case of 2010, the value of donated property was less than KRW 100 million, and was excluded from taxation.” [Attachment 2]