1. The Defendant’s disposition of imposition of acquisition tax of KRW 20,126,290 against the Plaintiff as of December 10, 2015 shall be revoked.

2...

1. Details of the disposition;

A. The total number of shares issued at the time of incorporation on July 4, 1994 was 150,000 shares of a stock company B, the representative director of which is the Plaintiff (hereinafter “B”).

B. At the time of incorporation B, the Plaintiff held 45,00 shares, C, 15,00 shares, D, 22,50 shares, E, F, G, and H respectively, 15,00 shares, and I held 7,50 shares, respectively.

C. D received 3,00 shares for capital increase on January 15, 1999 on January 15, 1999; 10,000 shares for capital increase on January 12, 200; 3,98 shares for capital increase on February 23, 2002; 16,952 shares for capital increase on April 1, 2002; 11,966 shares for capital increase on November 2, 2004; and 68,406 shares for capital increase on September 30, 2013; and J acquired 15,00 shares for capital increase on September 9, 199; and thereafter, acquired 15,00 shares for capital increase on February 23, 200; 193 shares for capital increase on April 1, 2005; 200 shares for capital increase on March 16, 2005; 200 shares for capital increase on May 13, 2018, 20014

(D) Each shares of the D and J ("the shares of this case"), D. D.

On July 2013, the Central Regional Tax Office conducted a tax investigation on B, and in the course of the tax investigation, title trust of the instant shares was subject to investigation. On September 2, 2013, D and J submitted a written confirmation to the public official of the Central Regional Tax Office that all the shares held by the principal with respect to B were entrusted by A upon A’s request, and that the actual owner was A and that there was no contribution and capital increase with respect to capital was paid by the principal.

E. As a result of tax investigation, the Central Regional Tax Office determined that the Plaintiff trusted the instant shares to D and J.

F. Accordingly, the Central and Medium Regional Tax Office applied the provision on the constructive gift of trust property under the Inheritance Tax and Gift Tax Act to ① the acquisition by transfer to J in 1999, the capital increase by free in 2002, and the capital increase by free in 2004 as to the capital increase by free in 2004, and imposed gift tax on J. 5-2 as deemed donation 23,848 capital increase by free contribution in 204.