1. Gift tax amounting to KRW 6,427,431,600 (including additional tax) imposed on Plaintiff A on December 12, 201 by the director of the regional tax office of the regional tax office.

1. Details of the disposition;

A. On August 11, 197, C established D Co., Ltd. (hereinafter “instant company”) on December 28, 1992, and held a title trust with Plaintiff A, a partner, and 300 shares of the instant company, respectively.

B. On June 28, 1996, Plaintiff A accepted 46,000 shares and Plaintiff B accepted 20,000 shares in the process of capital increase with compensation for new shares issued by the instant company, respectively. On December 15, 2000, Plaintiff A accepted 1,106,300 shares and Plaintiff B accepted 481,00 shares in the process of capital increase with compensation for new shares issued by the instant company.

C. The Director of the Seoul Regional Tax Office from March 4, 2010 to the same year

6. Before conducting a tax investigation by December 28, 200, C notified the Plaintiffs of the result of the tax investigation that C would impose gift tax according to the constructive gift of title trust property by deeming that C had trusted the shares of the instant company held by the Plaintiffs under the Plaintiffs

Accordingly, on December 12, 201, the head of the regional tax office decided to impose the gift tax of 6,427,431,600 won on the Plaintiff on June 28, 1996, and the gift tax of 30,611,514,010 won on the donation on December 15, 200, and served a notice for tax payment to Plaintiff A on the same day. On December 1, 2011, the head of the regional tax office sent a notice for tax payment to the Plaintiff on the same day. On December 28, 2011, the head of the regional tax office: (a) determined to impose the gift tax of 2,752,92,92,00 won on the gift on the Plaintiff on June 28, 1996; and (b) determined to impose the gift tax of 13,305,125,90 won on the gift on the December 15, 2000.

On March 8, 2012, the Plaintiffs filed a request for review of the said taxation by the Board of Audit and Inspection, and on May 14, 2014, the Board of Audit and Inspection rendered a decision to revoke the respective portion of the gift tax on December 15, 200 among the said taxation dispositions on the grounds that the shares acquired by the Plaintiffs during the process of gratuitous increase was not subject to a provision on deemed donation.

(hereinafter referred to as “instant disposition”). [The grounds for recognition] of absence of dispute, Gap evidence Nos. 1, 2, and Eul evidence Nos. 5 and 8.