A. On March 31, 2012, the Plaintiff and Nonparty D, Plaintiff A, and Plaintiff C agreed to acquire each of the 9,000 shares issued by F Co., Ltd. (hereinafter “F”) from D respectively at KRW 5,000 per share with a face value of 1,00,000 per share, and Plaintiff B signed a share transfer contract to acquire each of the 7,980 shares issued by F from the same day at KRW 5,00 per share with a face value of 5,00 per share (hereinafter “each of the instant contracts”).

B. Since then, the director of the Central Regional Tax Office of China: (a) was suspected of proving that the Plaintiffs had received profits from the acquisition of F’s shares from D and E (Plaintiff A, Plaintiff C, Plaintiff B, Plaintiff B7,980 shares, and each of the above shares “instant shares”) at low prices; (b) made a written confirmation with respect to the Plaintiffs and F from March 12, 2015 to April 8, 2015; (c) however, the Plaintiffs were converted to the on-site investigation to be conducted from July 20, 2015 to August 18, 2015, without any particular explanation as to the acquisition process by the Plaintiffs. < Amended by Act No. 13482, Jul. 20, 2015>

C. As a result of the investigation of stock change, the Director of the Central Regional Tax Office determined that D/E held the shares of this case in title trust to the Plaintiffs, and notified the Defendant of the taxation data.

Accordingly, on December 1, 2015, pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter the same) (amended by Act No. 13557, Dec. 15, 2015; hereinafter the same), the Defendant issued a notice to Plaintiff A of gift tax of KRW 5,366,520,360 (including additional taxes) on the donated portion on March 31, 2012; KRW 4,666,747,730 (including additional taxes) on the donated portion on March 31, 2012; and KRW 5,36,520,360 (including additional taxes) on the donated portion on March 31, 2012 to Plaintiff C, respectively.

(hereinafter “each disposition of this case”). (e)

On February 26, 2016, the plaintiffs filed an appeal with the Tax Tribunal, but dismissed the plaintiffs' appeal on June 14, 2016.

[Ground of recognition] A without dispute, and where there are evidence Nos. 1 and 8, the number shall be included, below.