1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From March 30, 2010, the Plaintiff is serving as an internal director of a corporation B (the trade name of October 10, 2012 was changed to “stock company C”; hereinafter “B”).

B. On October 19, 2010, the Plaintiff acquired 4,000 shares of B from the former representative director D in B (the share ratio of 40%; hereinafter “instant shares”) in total of 75,000 won per share.

C. On Nov. 201, 2016, the head of the Chungcheong District Tax Office conducted an investigation into gift tax on the Plaintiff. On Dec. 31, 2016, the head of the Chungcheong District Tax Office notified the Defendant of the taxation data of KRW 1,353,400,00 as the transfer value of the instant shares, including the additional tax on December 11, 2016, pursuant to the supplementary assessment method under Article 63(1) of the Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 2011; hereinafter “Gift”) and Article 54(1) of the Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 22579, Dec. 30, 2010; hereinafter “Enforcement Decree of the Inheritance Tax and Gift Tax Act”). The Defendant notified the Defendant of the additional tax on the acquisition of the instant shares as the transfer value of the instant shares.

(hereinafter “instant disposition”) D.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal, but was dismissed on December 28, 2017.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 4, 14, 15, Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s instant disposition is unlawful for the following reasons.

1. B’s former representative director D transferred the shares of this case to the Plaintiff as it is difficult to continue its business due to health problems, and the sales of B sharply decreased and incurred before the deadline for reporting the gift tax base following the Plaintiff’s acquisition of the shares of this case.