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

A. The details of changes in the stocks reported by Nonparty B Co., Ltd. (hereinafter “Nonindicted Company”) at the time of filing a corporate tax return are as follows.

(1) At the time of the incorporation of the shareholder, Plaintiff 2,900 2,900 2,900 2,900 2,900 C 2,000 D 2,100 4,100 4,100 4,100 E 3,000 3,000 3,000 3,0000 F.3,000 3,000 (1) is for Mable milk Co., Ltd. 3,3,000 (2) small 10,000 (10,000 10,000 10,000: 10: E, the representative director of the non-party company, as the representative director of the non-party company, transferred the shares of the non-party company to Non-party 2,500,000 won (hereinafter “the shares of this case”) x the non-party 2,500,00 won (hereinafter “the non-party 1”).

B. The director of the Seoul Regional Tax Office concluded, from May 2, 2013 to June 30, 2013, that “The actual owner of the instant shares at the time of the establishment of the Nonparty Company was not E but Nonparty G, the father of the Plaintiff, and that the transfer of the instant shares to F on December 16, 2002 was actually a donation by G to the Plaintiff.” This fact was notified to the Defendant.

C. Accordingly, on August 1, 2013, the Defendant decided and notified the Plaintiff of KRW 889,424,080 as gift tax.

(hereinafter “instant disposition”) D.

On October 24, 2013, the Plaintiff filed an appeal with the Tax Tribunal on the instant disposition, but was dismissed on July 9, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 1-1, 2, Gap evidence 2, 3, Gap evidence 4-1 to 4, Eul evidence 1, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. At the time of the Plaintiff’s establishment of Nonparty 1 Company, the actual owner of the instant shares was E, and the Plaintiff purchased the instant shares from E on December 16, 2002 and thereafter to F.