1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. A. B (hereinafter “B”) is a company incorporated on April 27, 2004 with capital of KRW 100 million (in 20,000,000) for the purpose of the automobile parts manufacturing business, etc., and C is a representative director and a shareholder of B, and is substantially managing the company.

on April 27, 2004, the number of shares issued in the Plaintiff’s name (capital) increased on April 27, 2004, 50,000 capital increase on June 16, 2004 (200 million won) 5,000 capital increase on April 4, 2006, 52,000 (260 million capital increase) on April 4, 2006 (40 million won) of April 15, 2006, 100 capital increase on April 15, 2006 (40 million won) of April 29, 2008.

B. B, after its establishment, offered capital increase as listed below, and during that process, B’s stocks in the name of the Plaintiff were also increased as stated above.

C. The Defendant: (a) deemed that all shares in the Plaintiff’s name were trusted in the Plaintiff’s name, a real owner; and (b) imposed gift tax on the Plaintiff on September 12, 2012 pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”); (c) however, in 2004, 10,000 shares issued in the Plaintiff’s name were all issued on April 27, 200, with the knowledge that they were issued on two occasions; and (d) calculated and imposed gift tax as follows.

[Details of Determination and Notice of Gift Tax] - 10,437,00 won for gift on April 27, 2004 - 18,58,960 won for gift on April 15, 2006 - Amounting to 90,620,860 won for gift on April 29, 2008

D. The Plaintiff, who was dissatisfied with the imposition of each gift tax as above, filed an objection on November 29, 2012, and filed an appeal with the Tax Tribunal on January 14, 2013. However, the said claim was dismissed on March 20, 2013.

E. Meanwhile, the Defendant confirmed mistake related to the issued shares in 2004, and decided to reduce KRW 5,218,500 as to KRW 10,437,00 of the gift tax on April 27, 2004 at the first time on August 12, 2014, and issued a new notice of KRW 6,250,250 on June 16, 2004.

(c).