1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. Details of the disposition;

A. On or before the death of February 21, 2007, the net C (D)’s referenced by the Plaintiffs (hereinafter “instant shares”) acquired and managed 2,035,570 shares of E Co., Ltd. (securities listed corporation, and hereinafter “instant company”) under its control under the name of nine former and incumbent executives, employees, and other persons, such as the list of the attached taxation disposition.

B. As the deceased on February 21, 2007, the instant shares were inherited by the deceased C’s heir (hereinafter “the first inheritance”), and thereafter, the deceased F managed the instant shares, and on November 4, 201, the part of the instant shares inherited by the deceased F among the instant shares upon the death of the deceased RF was inherited to the Plaintiffs, who are their children.

(hereinafter referred to as "re-Succession"). (c)

With respect to the title trust of the instant shares with nine title trustees before the commencement of the first inheritance on February 21, 2007 due to the death of the deceased C, the Defendants imposed and collected gift tax on the title trustee by deeming that the deceased C, a de facto owner on the date of change of ownership on the registry of the instant shares, donated the relevant shares to the title trustee pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”).

At the same time, the Defendants imposed and collected gift tax of KRW 4,228,798,861 on the deceased C or the plaintiffs as joint and several taxpayers for the above nine trustees.

Since then, on February 21, 2007, the first inheritance date, the Defendants deemed the acquisition date of the instant shares by the Plaintiffs, who are successors, and on the grounds that the said nine-person’s title trustee did not transfer his/her name by the last day of the year following the acquisition date ( December 31, 2008), imposed another gift tax on the said nine-person’s title trustee. The Defendants also were the deceasedF or the deceased on February 13, 2013.