1. The Defendant’s gift tax on August 11, 2015 for the Plaintiff KRW 732,925,170, and gift tax for the year 2014 for the Plaintiff on August 11, 2015, KRW 502,322.

1. Details of the disposition;

A. On October 9, 2012, with respect to land B and 26 parcels in the Plaintiff’s name, each registration of ownership transfer was completed on January 29, 2014 (hereinafter “instant land”), including B and 26 parcels.

B. After investigating the Plaintiff’s property acquisition fund, the director of the tax office imposed gift tax on the Plaintiff on the Plaintiff by deeming that the Plaintiff received each gift of KRW 2240 million from the husband D in 2012, and KRW 936 million in 2014, respectively, and notified the Defendant of the imposition of gift tax by deeming that the Plaintiff acquired each of the instant land. On August 11, 2015, the Defendant issued a disposition imposing gift tax of KRW 732,925,170 in 2012, and KRW 502,322,940 in 2014 (hereinafter “instant disposition”).

C. The Plaintiff filed an appeal with the Tax Tribunal on January 19, 2016 on the instant disposition on September 22, 2015, but the Tax Tribunal dismissed the Plaintiff’s appeal on June 7, 2016.

[Ground of recognition] No dispute, Gap evidence Nos. 1 through 4 (including paper numbers), Eul evidence Nos. 1 and 2, and the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The gist of the Plaintiff’s assertion is only the land registered in title by D, not the land acquired by the Plaintiff after receiving a donation of the purchase price from D.

B. In light of the following circumstances acknowledged in light of the respective statements and arguments stated in the evidence Nos. 5 through 28 as well as the purport of the entire pleadings, the instant land is deemed the land trusted in trust to the Plaintiff by D, and cannot be deemed the land acquired by the Plaintiff after receiving a donation from D. Therefore, the Plaintiff’s assertion is reasonable, and thus, the instant disposition should be revoked as it is unlawful.

1. The funds to acquire the instant land were borrowed from Company E, a corporation in which D owns 64.3% of the shares, or obtained loans from the NAFFF, and the purchase price of the instant land is D.