A. On May 28, 2012, Plaintiff’s mother B, the father of the Plaintiff (hereinafter “the decedent”) reported inheritance tax to the Director of the competent Tax Office with the taxable amount of inheritance tax of KRW 8,923,702,784, and the payable tax amount of KRW 1,970,369,843 as of November 30, 2012, following the death of Plaintiff’s father C (hereinafter “the decedent”).

B. From May 22, 2013 to September 4, 2013, the director of the Central Regional Tax Office verified that the Plaintiff’s debt 2,208,691,506 won (hereinafter “instant debt”) secured by the Plaintiff’s debt 6,188m2 (hereinafter “instant land”) prior to GY-si, Young-si, the inheritee owned by the inheritee was changed to the name of B and E, the Plaintiff’s spouse, and notified the Defendant of the taxation data.

C. Accordingly, on October 14, 2012, the Defendant deemed that the amount equivalent to the instant debt constitutes a gift profit from the exemption of obligation, etc., and accordingly, deemed that the amount equivalent to the instant debt constitutes the gift tax of KRW 156,91,494, and KRW 49,675,166 (including additional tax) for the gift tax of the E-donation portion as of December 10, 2012, and notified the Plaintiff of each correction and notification.

(hereinafter collectively referred to as “instant disposition”)

D. On June 24, 2014, the Plaintiff appealed against the Plaintiff and filed a request for a trial with the Tax Tribunal. On May 28, 2015, the Tax Tribunal dismissed the Plaintiff’s request.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence Nos. 1 through 5 (including each number), the purport of the whole pleadings

2. The Plaintiff asserted that he had borne a large amount of debt including the instant debt due to his failure of business before the death of the inheritee. However, in order to prevent the bond company, etc. from going against the Plaintiff’s share of inheritance, the inheritee prepared a testamentary document and inherited the instant land equivalent to the Plaintiff’s share of inheritance to E and son F (Acquisition by the renunciation of inheritance by F) who was satisf without succeeding to the Plaintiff.