Litigation costs shall be borne by the plaintiff.

A. On October 14, 2013, the Plaintiff entered into a lease agreement with the Seoul Gangnam-gu Seoul Metropolitan Government (hereinafter “instant real estate”) with the deposit amount of KRW 440 million with respect to the lease deposit (hereinafter “deposit”) on the building D (hereinafter “instant real estate”); on September 20, 2014, the lease agreement between E and the Songpa-gu Seoul Metropolitan Government F building G (hereinafter “instant real estate”) with the deposit amount of KRW 580 million; on April 18, 2016, H and I purchased the building D (hereinafter “instant real estate”). The Plaintiff acquired the instant real estate from H and I (hereinafter “instant real estate”). < Amended by Presidential Decree No. 27417, Jul. 15, 2016; Presidential Decree No. 27420, Mar. 6, 2016; Presidential Decree No. 27805, Apr. 18, 2016; Presidential Decree No. 27800, Mar. 6, 2000, 2000

B. From April 18, 2018 to June 27, 2018, the director of the Seoul Regional Tax Office: (a) conducted an investigation into the source of funds for each of the instant real estate deposits and acquisition funds; (b) conducted an investigation into the source of funds for the Plaintiff; and (c) conducted an investigation into the same purport of Article 45(1) of the Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015); and (d) accordingly, the purport of Article 45(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec

(2) Pursuant to Article 34(1) of the former Enforcement Decree of the Inheritance and Gift Tax Act (amended by Presidential Decree No. 30391, Feb. 11, 2020; hereinafter the same), the real estate deposit and the acquisition fund of the real estate of this case were calculated as the value of the Plaintiff’s donated property and notified the taxation data.

C. Accordingly, the Defendant: (a) deemed that the Plaintiff was donated KRW 46 million on November 19, 2014, which was transferred to the instant real estate from L, M, his parent, and KRW 376 million on July 15, 2016, respectively; and (b) on October 8, 2018, the Defendant deemed that the Plaintiff was donated KRW 110,297,80, and the gift tax (including additional tax; hereinafter the same shall apply) donated in November 2014 on the gift donated in July 2016 to the Plaintiff and KRW 91,163,520, and the gift tax donated in November 2016 to the Plaintiff.