1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From November 22, 2016, the director of the Seoul Regional Tax Office conducted an investigation of stock change (hereinafter “instant investigation”) with respect to Company B (hereinafter “Nonindicted Company”). On March 7, 2013, the Plaintiff’s 44,000 shares of the non-party company (hereinafter “instant shares”) acquired from the Plaintiff’s spouse and the largest shareholder of the non-party company C were listed on the D market. As such, the Plaintiff obtained “interest arising from the listing of shares” subject to gift tax pursuant to Article 41-3 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11845, May 28, 2013; hereinafter “Capital Gift Tax Act”) and notified the Defendant of taxation data.

B. On May 10, 2017, the Defendant calculated the gift tax base of KRW 6,027,804,152 on the profits accrued from the listing of the instant shares (hereinafter “listed profits”) (i.e., the taxable value of donated property 6,057,804,152 - the deductible amount of the donated property excluding any summing-up pursuant to Article 55(1)3 of the Inheritance and Gift Tax Act - KRW 30,000 on the donated property excluding any summing-up pursuant to Article 55(1)3 of the Inheritance and Gift Tax Act, and notified the Plaintiff of KRW 3,303,303,727,725 of the gift tax, including the gift tax amount of KRW 510,780,415, and additional tax without filing a return.

(hereinafter “instant disposition”). C.

On August 7, 2017, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on August 7, 2017, but the Tax Tribunal dismissed the Plaintiff’s claim on December 6, 2017.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1, 2, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Summary of the plaintiff's assertion

A. Chapter 1 and Section C’s account H, the Plaintiff’s principal transaction account, between April 9, 2010 and February 9, 2011, for the payment of lease deposit (hereinafter “instant deposit”) under Gangnam-gu Seoul E apartment F (hereinafter “instant apartment”) that will move into around February 10, 201.