1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On April 12, 2010, an unlisted company (hereinafter “instant company”) issued new shares in KRW 10,000 per share when the Plaintiff owned 29%, B 51%, and C owned 20%.

B. At the time of capital increase with new shares as above, B and C renounced each of 60,741 shares and 23,820 shares, the Plaintiff acquired the forfeited shares of 84,561 shares (hereinafter “instant shares”) at KRW 10,000 per share.

(hereinafter “instant new shares”). C.

The Plaintiff deemed the value per share of the instant shares as KRW 12,372, and reported and paid gift tax of KRW 34,220,226 (including additional tax) to the Defendant on August 31, 2012, by deeming the difference between the acquisition value and the acquisition value as KRW 200,578,692 (=(12,372 - 10,000) x 84,561) as the value of donated property.

The Defendant assessed the value per share of the instant shares as KRW 21,610 according to the supplementary assessment method under Article 63 of the Inheritance Tax and Gift Tax Act (hereinafter “Inheritance Tax Act”). On October 9, 2012, on the ground that the Plaintiff acquired the instant shares from B and C at a price lower than the market price, and thus, deemed that the Plaintiff received the shares from B and C and received the amount equivalent to the difference as a donation, and imposed an imposition and collection on the Plaintiff on October 9, 2012 (i.e., KRW 171,110,240 for the portion of C gift (= KRW 65,246,450 for the portion of C gift).

(hereinafter “instant disposition”) e.

On December 11, 2012, the Plaintiff appealed and filed a request for adjudication on December 11, 2012. On March 24, 2014, the Tax Tribunal rendered a decision that “In assessing the value per share of the instant shares, 356,170,386 won (sales bond 36,540,193 won, inventory asset 302,26,300 won, advance payment expense, 17,363,893 won) shall be deducted from the asset value, and the tax base and amount shall be corrected by adding the retirement benefit allowance to KRW 9,628,830 from the debt value, and the remaining claims shall be dismissed.”

F. According to the decision of the said Tax Tribunal, the Defendant: (a) KRW 157,90,720 from KRW 236,356,690 to KRW 157,90,720 on April 8, 2014 = B donated portion.