1. The following parts of the disposition imposing capital gains tax for the year 201, which the Defendant rendered to the Plaintiffs on November 1, 2013, are as follows:

1. Details of the disposition;

A. On May 31, 2005, the Plaintiffs acquired 13,000 shares of the total stocks of the non-listed corporation (hereinafter “instant shares”) 13,000 shares of the non-listed corporation (hereinafter “non-listed corporation”) from C and two other (hereinafter “former transferor”) (hereinafter “the instant shares”) and transferred the instant shares to D and one other (hereinafter “transferee”) on March 15, 201.

B. On May 31, 2011, the Plaintiffs calculated a total of KRW 3,766,80,000, and the transfer value of the shares in this case as stated in the Plaintiffs’ declarations under the following Table 1 to the Defendant, and filed a return on the tax base of transfer in Mus, by calculating the total of KRW 3,410,000,000.

The details of the plaintiffs' report on correction of the defendant (acquisition value) shall be the transfer value of the tax amount imposed on the plaintiff A 1,921,073, 390 1,739, 104, 410 1,451, 766, 000, 747, 860 plaintiffs B 1,845, 726, 610, 670, 895, 5901, 394, 394, 834,000 36,254, 3666, 80, 800, 376, 800, 410, 2846, 600, 600,000

C. However, as a result of the examination of the transferor prior to the instant shares transfer, the Defendant determined the transfer value (i.e., the Plaintiffs’ acquisition value) of the instant shares as KRW 2,846,60,000, and accordingly, on November 1, 2013, the Defendant issued a correction and notification of the transfer income tax for the year 201 (Plaintiff A37,747,860, Plaintiff B36,254,170, and Plaintiff B36,254,170) calculated by revising the acquisition value as stated in the Defendant’s correction statement in the Table 1.

【Unsatisfied Facts, Gap 1, 2 evidence, Eul 1 to 3 evidence (including each number; hereinafter the same shall apply)

2. Whether the instant disposition is lawful

A. The plaintiffs' assertion of this case is erroneous in the calculation of the acquisition value and transfer value as follows, so it should be revoked illegally.

(1) As to the acquisition value, the Plaintiffs shall be determined as KRW 3,766,800,000 for the shares of this case between the transferor and the former transferor, provided that such determination is made.