1. The plaintiff (appointed)'s claim is dismissed.

2. The costs of lawsuit shall be borne by the plaintiff (appointed party).

1. Details of the disposition;

A. On May 15, 2008, the Plaintiff and the designated parties who were the shareholders of F Co., Ltd. (hereinafter “instant company”) signed a share transfer agreement with the Plaintiff and the designated parties E, who were their children, the spouse of the son C, the Appointor C, the fourth degree of co-spouse C, the son’s spouse, as indicated in the table below, to transfer 136,500 shares of the instant company (hereinafter “instant shares”) owned by them in total of KRW 1,365,00,000, and transferred the same content on May 26, 2008.

Transferable and transferee’s transfer value (won) E B B 22,000 2220,000,000 C 222,000 C 220,000,000 D 35,000 D 35,000,000 A B 57,500,000 A B 57,5005,000,000,000

B. Meanwhile, the director of the Daejeon Regional Tax Office conducted an investigation on the change of stocks with respect to the instant company, and confirmed that the Plaintiff, the Plaintiff, and the selected parties E did not transfer the instant stocks to the designated parties B, C, and D, and notified the Defendant of the fact of title trust. The Defendant applied the provision on the constructive gift of title trust under Article 45-2(1) of the Inheritance Tax and Gift Tax Act (hereinafter “Inheritance Tax Act”) to the designated parties B on July 17, 2012, imposed the gift tax of KRW 169,040,630 on C on the same day, and KRW 267,646,100 on August 2, 2012, and imposed a joint and several disposition of imposition of gift tax of KRW 534,220,980, and KRW 315,923,430 on the same day to the designated parties C on the same day, and on July 17, 2012, each of the aforementioned persons liable for tax payment.

(hereinafter referred to as "each disposition of this case" in total of the above dispositions.

Plaintiff

The designated parties, who are dissatisfied with each of the dispositions of this case, filed an objection to the Defendant on October 10, 2012, but they were dismissed on November 7, 2012, and subsequently filed an appeal with the Tax Tribunal on February 5, 2013, which was dismissed on May 13, 2014.

[Reasons for Recognition] Facts without dispute, Gap evidence 1 to 3, and 7 (if there are serial numbers, including branch numbers; hereinafter the same shall apply) and Eul evidence 1, 2, and 7.