1. Revocation of the first instance judgment.

2. Attached Form 2. As to the Defendant’s heir of the deceased H on September 22, 2014.

1. Details of the disposition;

A. The plaintiffs' status 1) B Co., Ltd. (hereinafter "foreign company")

On January 12, 1990, the non-party company was established with the trade name of JJ Co., Ltd., and changed the trade name to C on June 5, 1996, and was changed to the trade name as of April 28, 2015.

(2) The Plaintiffs, as the believers of the Plaintiff’s Intervenor’s Intervenor, are registered as shareholders in the register of shareholders of the non-party company. Of [Attachment 1] to 64 (“Plaintiff 1 through 64”) all the Plaintiffs listed in [Attachment 1] as shareholders of the non-party company, are registered as shareholders in the register of shareholders of the non-party company. Plaintiff E is registered as shareholders in the same aggregate as indicated on the register of shareholders of the non-party members of the employee stock ownership association “members of the non-party stock ownership association”. Plaintiff E is 40,000 weeks, Plaintiff G is 50,000 weeks, and Plaintiff F is registered as shareholders of the non-party

(hereinafter referred to as “the shares”) of this case. (B) The aggregate of the shares shall be 180,000 shares.

1) The director of the Seoul Regional Tax Office (hereinafter referred to as “the deceased”) who was a parent of the M Group from April 22, 2014, and died on or around July 2014 (hereinafter referred to as “the deceased”).

After conducting a tax investigation on the deceased, the Defendant notified the Defendant of the gift tax assessment data stating that “the deceased was provided with the exhibition service free of charge by a person with a special relationship.” (2) On July 1, 2014, the Defendant decided and notified the deceased of KRW 15.35 billion of gift tax on the deceased.

However, on July 2014, the deceased was revealed to be dead, and the Defendant cancelled the imposition of the above gift tax on the deceased, and began to impose a seizure disposition on the inherited property on the premise that the inheritor is liable to pay the gift tax of KRW 13.663 billion, which is anticipated to be succeeded to the deceased’s heir, within the limit of the inherited property.

C. The delinquent taxpayer: BZ (the wife of the net), CA, CB,CC, and CD (the deceased’s children): The deceased’s indication of the attached property worth KRW 13.663 billion from time to time in January 201 of the expected national tax on gift tax.