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

A. On December 24, 2012, the Plaintiff: (a) engaged in the manufacturing of automobile parts in the name of “C” and “D” (the Plaintiff’s joint representative; hereinafter the Plaintiff’s representative) in the member-gu land and its ground buildings (hereinafter “instant real estate”); (b) established “F of the Company” (hereinafter “instant company”) on March 7, 2013 by investing in kind the instant real estate in kind on the part of December 24, 2012.

B. On January 31, 2013, the Plaintiff applied for the carried-over taxation of capital gains tax based on the special provisions on capital gains tax for corporate conversion prescribed in Article 32 of the former Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013).

On the other hand, Article 32(5)2 of the Restriction of Special Taxation Act amended on January 1, 2013, and Article 32(5)2 (hereinafter “instant provision”) newly established a provision that if a resident subject to the special case of carryover taxation of transfer income tax on the conversion into a corporation disposes of 50/10 or more of the stocks or equity shares acquired by conversion into a corporation within five years from the date of establishment of the corporation, he/she shall pay the carried-over and tax as transfer income tax when filing a tax base return for the taxable year in which the cause arises. Article 11 of the Addenda of the said Act provides that the instant provision shall apply to the portion of disposal of the stocks or equity shares acquired after January 1, 2013.

C. On December 30, 2012, the Plaintiff entered into a contract with the donee to donate 198,470 shares of the instant company (hereinafter referred to as “instant gift contract”) among 209,823 shares (total shares 227,016 shares, 92.4% of the total shares, 17,193 shares, and the remainder of 17,193 shares) to the management company G (34,052 shares), H (62 shares), H (34,052 shares), H (34,052 shares), I (34,052 shares), relatives J (34,052 shares) (hereinafter referred to as “beneficiarys”) (hereinafter referred to as “instant gift contract”), and filed a return and payment of gift tax on March 31, 2013.

The instant company shall complete business registration on December 29, 2012, which was before the registration of incorporation, and shall file a report on corporate tax for the business year 2012.