A. C is a manager of the G Group comprised of D Co., Ltd. (hereinafter “D”), E Co., Ltd. (hereinafter “E”), F Co., Ltd. (hereinafter “F”), and Plaintiff A is an employee of D, and Plaintiff B was a representative director of D from May 2006 to May 2010.

B. C, on November 30, 2007, title trust of 27,000 shares (30%) out of D’s 90,000 shares issued by it, was held by it to Plaintiff A on June 12, 2009, and 36,000 shares (40%) out of the remainder of issued shares were held by it to Plaintiff B on June 12, 2009.

(hereinafter referred to as “instant shares”) of each of the above shares which C held in title with the Plaintiffs.

The Defendants applied the provisions of Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”) to each of the above title trusts, and the Defendants: (a) on December 1, 2012, the head of Sungnam District Tax Office imposed and notified the Plaintiff of KRW 20,850,200 of the gift tax for 2007 and KRW 15,035,079 of the additional tax for 20,035,079 (=additional additional tax for 4,170,040,040 for additional tax for 10,865,039); and (b) on December 1, 2012, the head of the Defendant Nowonnam District Tax Office imposed and notified the Plaintiff of KRW 563,974,400 and additional tax for 308,408,79,798.198

On October 22, 2013, the Plaintiffs filed a petition for review with the National Tax Service on October 22, 2013, which was dismissed on July 11, 2014.

E. On September 2, 2014, the head of Sungnam District Tax Office issued a correction and notification of the amount of KRW 15,035,059 (19,205,059) for Plaintiff A’s additional tax (10,865,039 won for additional tax on additional tax on additional tax on KRW 8,340,080). The head of the Labor Relations Office issued a notice of correction and notification of the amount of KRW 308,465,798 as to Plaintiff B on September 3, 2014 = 421,514,466 won for additional tax on additional tax on additional tax on KRW 225,589,760 for additional tax on additional tax on additional tax on additional tax on KRW 195,924.