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

A. On June 3, 2008, the Plaintiff purchased from Yeongdeungpo-gu Seoul Metropolitan Government C Apartment 2206 (hereinafter “instant apartment”) at the price of KRW 500 million, and completed the registration of ownership transfer on June 30, 2008.

On the day of the contract, the Plaintiff paid the down payment of KRW 30 million on the day of the contract, and the intermediate payment of KRW 240 million on the part of the intermediate payment of KRW 200 million was substituted by the lessee’s acceptance of the obligation to refund the deposit to D, who is the mother of the lessee, and the remainder of KRW 230 million was paid on June 30, 2008.

B. At the time of the purchase of the apartment of this case, the Plaintiff received 49 million won from E, a major discount of the Plaintiff, and 50 million won from E, a smallest leakage, respectively, and used each of the above money as the purchase fund of the apartment of this case.

C. On May 1, 2014, the Defendant deemed that the Plaintiff donated each of the said money from E and F, and imposed gift tax of KRW 7,971,480 on KRW 49 million, and gift tax of KRW 9,058,500,000,000,000,000,000,000 donated from E, respectively.

(hereinafter “instant disposition”) D.

The Plaintiff filed an appeal with the Tax Tribunal on August 13, 2014 on the ground that the instant disposition was not received as a donation from E and F, but was borrowed, but the said money was dismissed on November 27, 2014 by the Tax Tribunal.

[Reasons for Recognition] Gap's Evidence Nos. 2, 3, 4, 7, 8, and Eul's Evidence Nos. 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. On March 19, 2003, the Plaintiff’s arguments D leased the instant apartment to KRW 240 million and resided in the instant apartment as well as the Plaintiff’s attached G around that time. As the lessor requested the eviction by selling the instant apartment, the Plaintiff purchased the instant apartment and determined the parent as the mother time.

The shortage of money is to borrow from the plaintiff E and F, who is the plaintiff, and the plaintiff's circumstances are to pay the borrowed money.