1. The defendant against the plaintiff:

A. The gift tax of January 12, 2012 exceeds KRW 2,934,00 out of the principal tax of KRW 3,276,00.

(g) On April 2, 2012, the Plaintiff appealed and requested the Tax Tribunal for a trial on April 2, 2012, but was dismissed on June 29, 2012.

H. Meanwhile, while the instant lawsuit is pending, the Defendant recognized that some errors were found in the initial evaluation method, and corrected the gift tax (including additional tax) on October 8, 2012 as indicated below, as follows.

(5) The amount of the principal gift tax that has been reduced at the beginning of the year shall be determined on December 31, 2004 by the average value of the last market value of the Korea Exchange from the date two months have elapsed before the base date of appraisal ( November 1, 2004) to the date before the date of termination of rights, as the average of the last market value of the Korea Exchange from the date when two months have elapsed after the base date of appraisal (269,277,076,934, 900* December 13, 2005) on March 15, 2005 to the date when two months have elapsed after the base date of appraisal (269,276,934, 900).

I. In addition, on December 11, 2012, the Defendant revoked ex officio the disposition imposing additional tax, and imposed and collected additional tax on January 11, 2013, stating the type of additional tax and the grounds for calculation thereof.

(2) Each of the following facts: (a) the imposition of gift tax in this case and the imposition of penalty tax as of January 11, 2013 are collectively referred to as “each of the instant dispositions”; (b) there is no dispute; (c) evidence Nos. 1 through 4; and (d) evidence Nos. 1 through 4 (including the serial number); and (c) the purport of the entire pleadings.

2. Whether each of the dispositions of this case is legitimate

A. Even if the non-existence of the Plaintiff’s assertion 1 tax avoidance purpose B acquired the title trust shares including the instant shares in its own name, it cannot be deemed that the Plaintiff did not fall under the oligopolistic shareholder of the instant corporation, and thus, did not go beyond the status of the oligopolistic shareholder with the secondary tax liability under the said title trust.