1. Defendant A and C entered into a contract on April 8, 2016 with respect to common shares 361,225 shares issued by D Co., Ltd.

1. Facts of recognition;

A. The parties’ relevant net F (hereinafter “the deceased”) died on March 23, 2015; C is the wife of the deceased; Defendant A is the head of the deceased; Defendant B is the grandchildren of the deceased.

B. The Seoul Regional Tax Office, under the Plaintiff’s taxation claim against C, has investigated the property inherited (the commencement date of inheritance: March 23, 2015) or donated (the date of acquisition of donated property: March 10, 2015) from the Deceased. The head of the Plaintiff-affiliated Racing Tax Office, on March 2, 2016, issued a notice of each determination that C shall pay gift tax of KRW 2,322,401,60 (including additional charges) and on May 2, 2016, the inheritance tax of KRW 53,653,381,690 (including additional charges) was to be paid by C. The said inheritance tax was reduced by KRW 53,653,381,690, and KRW 53,241,15,806, and KRW 53,285,285,381,465,5365,5365,51,205).

(In total, gift tax and inheritance tax claims (hereinafter “instant tax claim”). The due date for the payment of delinquent amount (including additional dues) on March 2, 2016 on the date of notification of the tax item, KRW 58,452,78,650 in total, KRW 57,269,272,00 on May 2, 2016, the inheritance tax of KRW 1,183,516,63,516,630 on March 31, 2016.

C. On April 8, 2016, C entered into a share sales contract between C and the Defendants, etc., and between Defendant A and Defendant A, “C sells 361,225 shares of common shares issued by D Co., Ltd. (hereinafter “instant 1 shares”) owned by Defendant C to KRW 6,200,000,000.”

(2) On April 28, 2016, Defendant A entered into a transfer procedure for the said shares. (2) On April 28, 2016, Defendant B and Defendant B sold “C” for KRW 164,700,000 of the common shares of E-issuance of Co., Ltd. (hereinafter “instant 2 shares”) owned by Defendant C at KRW 650,000.”