1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. B, on December 15, 200, acquired 16,000 shares out of 32,000 shares issued by C Co., Ltd. (C Co., Ltd. on December 15, 2000 to D; hereinafter “D”), which is engaged in the manufacture and installation business of steel structure, and completed the transfer of each transfer in the name of E (D’s employees) as to the remaining 6,40 shares out of 32,00 shares issued by C Co., Ltd. (hereinafter “D”).

B. D’s new shares issued 67,000 shares with capital increase on February 4, 2002, and B accepted 13,400 shares among them under the name of the Plaintiff.

C. Around January 4, 2003, D issued new shares with capital increase of 5,000 shares with capital increase, and B accepted 500 shares among them in the name of the Plaintiff.

On November 8, 2007, the Plaintiff: (a) retired from D around November 8, 2007; and (b) transferred a change of ownership in the name of E, F, and G with respect to 20,30 shares (i.e., 6,400 shares 13,400 shares 50 shares; hereinafter “instant shares”) under the name of D’s employees.

E. The director of the Daegu Regional Tax Office confirmed that B made a title trust of D’s shares to the Plaintiff, etc., and notified the Defendant of the data for taxation. The director of the Daegu Regional Tax Office confirmed that B made a title trust of D’s shares from March 7, 2012 to April 20, 2012

F. On September 4, 2015, the Defendant rendered a disposition of imposition of gift tax of KRW 79,972,590 (including additional tax on return) (hereinafter “instant disposition”) by deeming that the Plaintiff, a title truster of shares, donated D shares from B pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 1357, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”).

G. The Plaintiff filed an objection against the instant disposition on October 6, 2015, but received a decision of dismissal on November 9, 2015, and filed a request for a tax trial on February 5, 2016, but received a decision of dismissal on April 27, 2016.

H. Meanwhile, around 2012, the title trust of D’s shares was sought against B, etc.