1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. The Plaintiff owned the shares of Samsung Electronic Co., Ltd., a listed corporation (hereinafter “Tsung Electronic”), and transferred the shares of 5,820 shares in 209, 2,180 shares in 201, 1,400 shares in 201, and 5,450 shares in 201 (hereinafter “instant shares”), respectively, in the stock market, and did not file a transfer income tax on the transfer thereof.

B. On July 2014, the Board of Audit and Inspection may apply the Plaintiff’s stock transfer (amended by Act No. 12738, Jun. 3, 2014; hereinafter “Income Tax Act”) to the Plaintiff’s stock transfer: Provided, That the former Income Tax Act (amended by Act No. 10408, Dec. 27, 2010); and the former Income Tax Act (amended by Act No. 9897, Dec. 31, 2009) to the portion of capital gains tax reverted for the year 209, respectively, on the basis of the said Income Tax Act, since the parts applied to the Plaintiff are almost the same.

Article 94(1)3 (a) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013; hereinafter “Enforcement Decree of the Income Tax Act”): Provided, That Article 94(1)3 (a) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 22580, Dec. 30, 2010); and Article 94(2) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 22034, Feb. 18, 2010); however, the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 22034, Feb. 18, 2010) shall apply to the

The Plaintiff is obligated to pay capital gains tax to the Plaintiff on the ground that the total market value of Samsung Electronic Holdings as of the end of each business year immediately preceding the business year in which the date of the transfer of the instant shares belongs exceeds 10 billion won, and the Plaintiff is obligated to pay capital gains tax to the Plaintiff.