1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. A Co., Ltd. (hereinafter “A”) is a company that has engaged in various clothes manufacturing and sales business, and the Plaintiff is a person appointed as a trustee in bankruptcy on February 19, 2013 by being declared bankrupt by the Busan District Court due to financial deterioration.

B. On July 8, 2009, as C’s children, the representative director of A, who is a related party, transferred to D 200,000 won per share of 1,807 won per share, and total of 361,40,000,000 won per share of non-listed shares under the former Inheritance Tax and Gift Tax Act (amended by Act No. 9924, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”).

C. In transferring the instant shares to D in KRW 361,40,000, A assessed the F’s assessment value per share on the ground that the F’s financial status as of the assessment base date ( June 30, 2009) is de facto capital erosion (i.e., the net asset value per share and the net profit and loss per share) against the total amount of 52,009 shares of unlisted company F (hereinafter “F”) owned by E (hereinafter “F”), as of June 30, 2009.

On the other hand, the book value of the F shares was KRW 1.3 billion. D.

As a result of conducting a tax investigation on the transfer of the stocks of this case to A at low price, the Defendant confirmed that the net asset value (0 billion won) of F was less than the book value (1.3 billion won) and calculated to A on December 10, 2012 as KRW 1.3 billion in book value pursuant to Article 55(1) of the former Inheritance and Gift Tax Act, the market value of the stocks of this case was calculated as KRW 1,011,40,000 (5,057 per share) according to the complementary assessment method under the former Inheritance and Gift Tax Act, by applying the provisions on the denial of wrongful calculation under the Corporate Tax Act. The Defendant applied the provisions on 650,000,000 = 1,01,40,000 - 361,401,400 -361,400.