1. On December 1, 2013, the Defendant imposed capital gains tax of KRW 386,014,040 on Plaintiff A for the year 2010, and imposed capital gains tax of KRW 74,927.

1. Details of the disposition;

A. The plaintiffs are major shareholders of D Co., Ltd. (trade name after the alteration: E, hereinafter referred to as the "instant company"), and the plaintiffs A are the mother of plaintiff B and C.

B. On April 19, 2010, Plaintiff A granted the right of representation on the loan to F, a financial director of the instant company, and F, on behalf of the Plaintiffs, on May 19, 2010, borrowed KRW 3.5 billion (hereinafter “the first loan contract of this case”) at the rate of 3.5 billion (hereinafter “the interest”) with the maturity of repayment from G, a corporate bond manager, August 18, 2010, and the interest rate of KRW 3.5 billion (hereinafter “the first loan contract of this case”), and offered KRW 3,634,08 of the shares of the instant company owned by the Plaintiffs as security.

The above loan agreement includes that “If the price of the shares offered as security changes rapidly and is less than 140% of the principal, and less than 1,348 won, the Plaintiff would not immediately offer an additional security, but G would sell the collateral shares and appropriate them for principal and expenses without prior notification to the Plaintiff, but the Plaintiff would not raise a civil or criminal objection.”

(hereinafter referred to as “a condition for the sale and disposal of secured shares” is C.

On the other hand, prior to the first loan contract of this case, Plaintiff A offered the company’s shares as collateral and borrowed KRW 3 billion from H from Plaintiff A, which was delegated by Plaintiff A, with the borrowed money under the first loan contract of this case, F repaid the borrowed money with the borrowed money under the first loan contract of this case, and received 1520,000 shares of the company of this case.

However, on July 8, 2010, in collusion with J, the head of the financial team of the instant company, and returned 600,000,000 won to the Plaintiffs, who were the Plaintiff’s children, during the said 1.520,000 weeks, provided as security to G without the Plaintiffs’ permission, and the payment period of KRW 1.9 billion was due on August 7, 2010, and interest was 3% per month, and then used as F’s acquisition cost.