1. Of the instant lawsuit, the part on which the Defendant sought revocation of the disposition imposing additional gift tax on December 1, 201.

Details of the disposition

On October 18, 2005, the father B of the Plaintiff imposed gift tax and additional tax on the Plaintiff received KRW 1,570,473,270 from the Korea Land Corporation as compensation for land in C district (hereinafter “instant compensation”).

The director of the Daejeon Regional Tax Office, from March 30, 2007 to May 10, 2007, conducted a tax investigation with respect to the Plaintiff. On November 15, 2006, he confirmed that B donated KRW 500,000,000 among the instant compensation to the Plaintiff in cash. Accordingly, on May 2007, the Defendant notified the Plaintiff of KRW 103,420,80 of the gift tax as to the donation of KRW 500,000 from B. The Plaintiff paid the full payment of the gift tax around that time.

Around May 201, the Defendant confirmed that the Plaintiff opened a borrowed account under the name of B and directly managed the money deposited and withdrawn from such account, and conducted a tax investigation on the Plaintiff from September 14, 201 to October 21, 201.

As a result, the Defendant confirmed the fact that the instant compensation was deposited in the accounts of the Daejeon District Branch in the name of NA, and that the sum of KRW 1,300,000,000,000, which is the Plaintiff’s head, was transferred to the bank account of D, and on December 1, 2011, the Defendant corrected the Plaintiff’s additional KRW 80,000,000, excluding KRW 500,000,000 already imposed gift tax, out of KRW 1,30,000,000, which was paid directly or through D, and notified the Plaintiff of KRW 600,195,60,000, after correcting the gift tax to KRW 603,420,80,00, the remainder of KRW 496,74,780,00 (the principal tax, gift tax,00,000, KRW 23274,780,00).

"Disposition on December 1, 201" is "Disposition on December 1, 2011," and "the part of the disposition imposing penalty tax" is "the first disposition."

(2) The Plaintiff’s objection and the Plaintiff’s re-disposition on February 8, 2012 filed an appeal with the Director of the Tax Tribunal against the disposition on December 1, 2011. However, the Director of the Tax Tribunal filed an appeal with the Director of the Tax Tribunal on October 1, 2013.