1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From March 28, 2005 to August 16, 2012, the Plaintiff served as the representative director of the Company B (the company name was changed to “C” in March 2013; hereinafter “B”) established for the purpose of research and development of cell therapy.

B. B issued bonds with warrants worth KRW 8 billion in total face value on December 29, 2009 (hereinafter “instant bonds with warrants”) (hereinafter “instant bonds with warrants”).

D Co., Ltd. (hereinafter “D”) acquired all of them, and sold them to E Co., Ltd. (hereinafter “E”) by separating only preemptive rights on December 30, 2009, and on the same day, the Plaintiff purchased from E the preemptive rights amounting to KRW 4 billion in total face value (hereinafter “instant preemptive rights”).

C. The Plaintiff exercised each of the instant preemptive rights on October 9, 2012 and October 30, 2012 as indicated below. D.

The Plaintiff: (a) deemed that the benefit falling under Article 40(1)2 of the Inheritance Tax and Gift Tax Act was donated by the exercise of the instant preemptive right as indicated in the table below; and (b) reported and paid KRW 7,941,189,800 on January 10, 2013.

E. On November 29, 2013, the Seoul Regional Tax Office conducted a tax investigation with respect to the Plaintiff, and notified the Plaintiff that the details of the Plaintiff’s gift tax return were appropriate (the disposition of this case was imposed as reported; hereinafter “instant disposition”).

F. On February 28, 2014, the Plaintiff filed a request for a trial with the Tax Tribunal, but the decision of dismissal was rendered on September 3, 2014.

[Ground of recognition] Facts without dispute, Gap's statements in Gap's 2 through 4, 6 through 12 (including branch numbers; hereinafter the same shall apply) and the purport of the whole pleadings

2. To make entries in the attached statutes concerned;

3. Whether the instant disposition is lawful

A. On September 28, 2009, B decided to issue the instant bonds with warrants (the chair, the representative director, and the same date) by the board of directors on September 28, 2009.