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

A. Relevant C Co., Ltd. (hereinafter “Nonindicted Company”) is a company engaged in the business of manufacturing automatic fire extinguishing devices.

D is the representative director of the non-party company, and the plaintiff A is the partner of the non-party company, and the plaintiff B is the wife of the plaintiff.

B. On August 22, 2008, Plaintiff B acquired 7,000 shares from E and 4,000 shares of Nonparty Company 20, 9,000 shares issued by Nonparty Company (45% shares) were owned by F, respectively. (2) On August 22, 2008, Plaintiff B acquired 7,00 shares from E and 4,00 shares from Plaintiff A, and 4,00 shares from F, the detailed statement of the change of shares was submitted to the head of competent tax office.

(hereinafter “instant shares”) 11,00 shares that were acquired under the name of the Plaintiffs (hereinafter “instant shares”).

1) The head of Seoul Regional Tax Office: (a) conducted an investigation into the change of shares with respect to the non-party company from August 29, 2014 to June 3, 2015; and (b) as a result, deeming that D had title trust with respect to the shares of this case for the purpose of evading D tax, the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter the same applies) deeming that D was a title trust

(2) In accordance with Article 45-2(1) of the former Inheritance Tax and Gift Tax Act, the Defendant notified the Defendant to the effect that gift tax should be imposed on the Plaintiffs by applying the provision on deemed donation of registered trust property under Article 45-2. (2) The Defendant evaluated the value of the instant stocks, which are non-listed stocks, as a supplementary assessment method pursuant to Article 60(1), (3), and Article 63(1) of the same Act, and then notified the Plaintiff of each determination and notification to the Plaintiff under the first sentence of Article 30,583,261 (including additional taxes for non-declaration and non-payment) of the former Inheritance Tax and Gift Tax Act as gift tax based on the donation made on August 22, 2008 (see Article 45-2(1) of the same Act, referring to each tax payment notice (including additional taxes for non-declaration and non-payment in good faith) and each determination and notification made on the Plaintiff’s first sentence (3).

In addition, the title truster D.