1. The Defendant imposed a gift tax of KRW 181,922,480 on the Plaintiff on November 7, 2013, KRW 151,740,559, which was imposed by the Plaintiff on November 7, 2013.

1. Details of the disposition;

A. B, on March 18, 2005, title trust was made to C with 8,000 shares issued bycom Co., Ltd. (hereinafter “instant shares”), but again, title trust was again made to the Plaintiff on December 27, 2010.

B. On November 30, 2012, the statutory due date of return, the Plaintiff received the instant shares from C, and reported and paid KRW 59,889,430,00, which is calculated based on the value of donated property as KRW 266,520,00 per share (assessment as KRW 33,315 per share).

C. After that, on November 7, 2013, the Defendant issued the instant disposition that determined and notified KRW 181,922,480 as gift tax for the year 2010, by adding the total amount of KRW 703,032,00,00, the value of donated property as of December 27, 2010, calculated as KRW 87,879 per share (assessment as KRW 87,879 per share) to KRW 150,90,60, and the amount of the tax already paid was deducted.

On June 16, 2014, the plaintiff appealed against the defendant and filed a request for a trial with the Tax Tribunal on June 16, 2014, but the request was dismissed on November 25, 2014.

[Ground of recognition] Uncontentious facts, Gap evidence Nos. 1 and 2, purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1) The Defendant’s assessment of the value of the instant shares did not add the estimated amount of an officer’s retirement allowance to the Defendant’s liability, thereby making an excessive assessment. 2) The Plaintiff filed a return after the deadline on November 30, 2012, which led to the under-reported return, merely resulted from the difference in the appraised value, etc., and thus imposing an additional tax on non-declaration of a report is unfair. Even if an additional tax should be imposed, it is unlawful to impose an additional tax on non-declaration of a report (40%) without imposing an additional tax on non-declaration of a report.

(b) as shown in the attached Form of the relevant statutes;

C. Article 17-2 subparagraph 3 (c) of the Enforcement Rule of the Inheritance Tax and Gift Tax Act as to whether the estimated amount of retirement allowance for executive officers should be added to the debt is at the time of assessing the value of unlisted stocks.