1. The Defendant’s imposition of gift tax amounting to KRW 7,921,50 on November 7, 2017 shall be revoked.

2. The costs of lawsuit shall be.

1. Details of the disposition;

A. B received a request from C to lend money on November 1, 2008, and received 100,000,000,000 from D Association on November 17, 2008, and from the Plaintiff, who is one of the Plaintiff, as the Plaintiff, respectively, borrowed 50,00,000 won from D Association on the same day. On the same day, C borrowed 150,000,000 won in total of the above loans (hereinafter “the instant loans”). As such, C was granted the following loans.

The next documentary evidence: The above amount was borrowed on November 17, 2008, in the daily KRW 150,000,000 (150,000), and the interest will be deposited into the D Association on 16th day of each month.

B. On June 17, 2012, C drafted a loan certificate with the following content (hereinafter “the instant loan certificate”).

The next documentary evidence: 150,000,000 Won (150,000,000) as of the due date for borrowing the above amount as follows: By December 31, 2014.

Interest: 7 Part A, the Plaintiff, N. H. L.

C. From January 3, 2012 to January 14, 2014, C paid interest on the instant loans to the D Association E account. D.

After that, upon the death of B on June 1, 2014, the Defendant: (a) donated the instant loan claim to the Plaintiff on January 15, 2014 by the net B (Finally, after receiving interest on the instant loan claim from C), and (b) remitted KRW 26,450,00 as the sum on September 25, 201 and March 6, 2012 to the Plaintiff’s account; and (c) donated KRW 38,46,970 in total by remitting KRW 11,96,970 on June 11, 2014, on the ground that the Plaintiff donated KRW 38,46,970 to the Plaintiff on November 7, 2017.

In addition, the Defendant recognized the amount of KRW 100,000,000,000, the taxable value of donated property related to the instant loan claim, which was created by the deceased B from the D Association under his name, as the substantial donated property.

Article 47 (2) of the Inheritance Tax and Gift Tax Act provides that the donor shall be a lineal ascendant within 10 years before the date of the donation.