1. On March 1, 2018, the Defendant imposed an inheritance tax of KRW 390,309,050 (including additional tax of KRW 822,659) on the Plaintiffs.

Details of the disposition

E Co., Ltd. (hereinafter referred to as “E”) was established on July 10, 2008 as an unlisted corporation for the purpose of printing, etc., and issued stock certificates around October 30, 2017.

F From January 1, 2012, G acquired 3,500 shares E (hereinafter “instant shares”) at par value of KRW 5,000 per share (total KRW 17,500,000). On July 5, 2013, H entered into a contract to transfer the instant shares at the same price (hereinafter “instant share transfer contract”).

After that, as the F (hereinafter “the deceased”) died on August 22, 2013, the Plaintiff B, C, and D, the deceased’s spouse, inherited the deceased according to their respective inheritance shares.

Meanwhile, as H did not pay the transfer price under the instant share transfer contract, the Plaintiffs filed a lawsuit against H seeking confirmation that the shareholders of the instant shares were the Plaintiffs, and filed a declaration of intent seeking the cancellation of the instant share transfer contract by serving a copy of the complaint, and the instant share transfer contract was rescinded on April 6, 2016.

On July 5, 2017, the Plaintiffs determined that the instant shares are included in inherited property and assessed the instant shares in KRW 2,592,146,749 according to the supplementary assessment method, and reported and paid KRW 383,541,540 of the inheritance tax on the inherited property equivalent to KRW 2,813,369,519 in total.

As a result of the inheritance tax investigation with respect to the Plaintiffs, the Defendant found that the cash was partially omitted among the deceased’s property, and included it in the inherited property, and determined and notified the Plaintiffs on March 1, 2018, an additional amount of KRW 6,767,510 (including additional tax of KRW 82,659) calculated by deducting KRW 383,541,540 as the above returned and paid tax from the Plaintiffs.

(hereinafter referred to as the “disposition of this case”). [Grounds for recognition] The Disposition of this case is without dispute, entry of Gap Nos. 1, 3 through 6, 9, and Eul No. 1 (including virtual numbers; hereinafter the same shall apply), and the purport of the Disposition of this case as a whole, before the issuance of share certificates of the plaintiffs' assertion as to the legitimacy of the Disposition of this case