A. On April 1, 2007, Plaintiff A entered a non-listed corporation C (hereinafter “instant company”) and is engaged in accounting and accounting affairs until now. Plaintiff B is the wife of D, the representative director of the instant company.

B. On April 27, 2010, the instant company issued new shares 15,000 shares (10,000 won per share) and issued new shares (hereinafter “instant new shares issued”). Based on the company’s list entered in the list of shareholders, the company’s structure and equity ratio of shareholders before and after the instant shares issued are as listed below.

(2) The number of shares issued by the Plaintiff and the number of shares issued by the Plaintiff is 2,000 shares issued by the Plaintiff in the name of the Plaintiff (hereinafter “instant shares”). The number of shares issued by the instant company prior to the offering of new shares by issuing new shares by shareholders is 2,500 D 12,500 shares ( per share) D 2,500 shares ( per share) D 12,500 60 representative directors E 1,500 30,000 1,000 2,000 2,000 2,000 2,000 (D’s shares) and 00 2,000 (D’s shares) 00 2,000 5,000 D’s shares held by the Plaintiff and the current status of shareholders. < Amended by Presidential Decree No. 17200, Oct. 10, 2005>

C. The Defendant imposed gift tax on the Defendant on the ground that the instant company issued new shares at a price lower than the market price in the process of issuing new shares during the capital increase with a view to obtaining profits from acquiring the instant shares out of 6,000 shares generated by the Plaintiffs’ waiver of the existing shareholders E andF’ rights to receive new shares, by applying Article 39(1)1(a) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201; hereinafter “former Inheritance Tax Act”), by applying Article 39(1)1(a) of the same Act, Article 29(3)1(a) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 23591, Feb. 2, 2012).