1. The penalty tax of KRW 58,776,720, which was paid to the Plaintiff A on December 1, 2016 by the director of the district tax office having jurisdiction over the gift tax of June 1, 2009.

1. Details of the disposition;

A. The registration of ownership transfer was completed on August 12, 1980 on the land of Gyeyang-gu Incheon Metropolitan City (hereinafter “instant land”). D (the Plaintiff’s punishment was omitted) due to trading on August 12, 1980.

B. D around June 12, 2009, sold the instant land in KRW 1.1 billion, and paid KRW 24.5 million out of the price to Plaintiff B on June 22, 2009, and KRW 23 billion to Plaintiff A on June 30, 2009.

C. On October 2016, the director of the Central Regional Tax Office of Central Regional Tax Office: (a) conducted a gift tax investigation on the Plaintiffs; and (b) notified the Defendants of the fact that “Seoul-do transferred the instant land donated by Da (referring to the Plaintiff and D; hereinafter “the network”; and (c) donated the relevant transfer proceeds to the Plaintiffs, who are births.”

Accordingly, on December 1, 2016, the director of the district tax office of Gangseo-gu imposed on the Plaintiff A a gift tax of KRW 58,776,720 (including penalty tax) on June 2009, and the director of the district tax office of Gangnam-do imposed on the Plaintiff B a gift tax of KRW 59,372,430 (including penalty tax) on June 2009.

(hereinafter “Disposition in this case”). 【No dispute exists, Gap 1, 3, Eul 1 through 3, and the purport of the whole pleadings

2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;

3. Whether the instant disposition is lawful

A. The gist of the plaintiffs' assertion 1 is unlawful to select the plaintiffs as the subject of tax investigation even though there is no ground to select the subject of tax investigation against the plaintiffs. 2) The land of this case constitutes inherited property since it is a property trusted by the deceased to D.

The deceased’s children, including the plaintiffs, agreed on the division of inherited property with D with respect to the land of Seoul Fdong and housing, inherited property, and the proceeds from the sale of the land of this case had other siblings except D.

Since the plaintiffs received a distribution of the proceeds from the sale of the land of this case according to the consultation, the plaintiffs cannot be deemed to have received property free of charge from D.

(b) 3, 9, 10 evidence 1-3, 9, 10 of the selection subject to the tax investigation is lawful.