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

E. The Plaintiff filed an appeal on April 2, 2012, but was dismissed by the Tax Tribunal on June 29, 2012.

F. On October 8, 2012, the Defendant changed the gift tax (including additional tax) by reducing or correcting the gift tax as indicated below attached Table 3.

(3) The gift tax on the gift tax on the date immediately before the base date of the appraisal ( February 6, 2005) shall be levied on December 1, 2004 as additional tax on the gift tax on the value per share as at the time of evaluation on the base date of the assessment on the gift tax (hereinafter referred to as the "disposition in this case"). < Amended by Act No. 731, Mar. 15, 2005; Act No. 7326, Mar. 15, 2005; Act No. 77745, Feb. 6, 2005; Act No. 77755, Feb. 4, 2005; Act No. 77855, Feb. 6, 2005; Act No. 77785, Feb. 4, 2005; Act No. 7783, Feb. 16, 2005; Act No. 7755, Feb. 4, 2005>

G. On December 6, 2012, the Defendant revoked ex officio the imposition of additional gift tax on each gift tax, and notified the Plaintiff of the second imposition of additional gift tax on the same amount.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 5, 11, 12, 13, 17, 20, Eul evidence 1, 2 and 3 (including provisional number), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion (1) The purpose of tax avoidance B is to participate in capital increase with a view to the rehabilitation of C and to hold more than 5/100 shares of a listed corporation, the Securities and Futures Commission and the Korea Stock Exchange should report the change in shares to the Securities and Futures Commission. As such, the title trust was made in order to avoid such reporting obligation, and the B came to go out of the status

As dividend income is distributed or dividend income, the cumulative tax rate shall be exempted in accordance with the global income cumulative taxation.