1. The Defendant’s disposition imposing gift tax amounting to KRW 903,987,650, which was imposed on the Plaintiff on December 10, 2012, shall be revoked.

2. The costs of lawsuit shall be.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “instant company”) is a corporation with capital of KRW 200 million established on February 1, 2009 for the purpose of manufacturing business, and the Plaintiff owns 40,000 shares, which are 10% of the total number of issued and outstanding shares.

B. On May 2, 201, C, the father of the Plaintiff, donated the following real estate (hereinafter “instant real estate”) to the instant company (hereinafter “instant donation”). The instant real estate is real estate leased to E, a corporation that C, while conducting real estate leasing business under the trade name D.

F G G H I F J K K

C. The instant company reported and paid KRW 472,598,676 of the corporate tax for the business year 201, after calculating the value of the instant real estate donated by C as an asset increase profit.

In the process of conducting a consolidated corporate tax investigation with respect to the instant company, the director of the Suwon Tax Office increased the value of the instant shares from 35,037 to 75,820 won per share due to the instant company’s donation of the instant real estate. The 40,783 won per share is a donation under Articles 2(3) and 42(1)3 of the Inheritance Tax and Gift Tax Act, and the Plaintiff’s donation of KRW 1,631,320,00 (the value per share 40,783 won x 40,000 per share x 40,783 won x 40,000), and notified the Defendant that gift tax should be imposed on the Plaintiff.

E. On December 10, 2012, the Defendant decided and notified the Plaintiff of KRW 903,987,650 of the gift tax regarding the gift of the instant real estate.

(f) (hereinafter “instant disposition”). On February 28, 2013, the Plaintiff dissatisfied with the instant disposition, filed an objection against the Defendant, but did not accept it. On June 24, 2013, the Plaintiff filed an appeal with the Tax Tribunal, but was dismissed by the said Tribunal on April 28, 2014.

[Reasons for Recognition] Unsatisfy, Gap evidence 1 through 5, and Eul evidence 1.