1.(a)

The defendant and the non-party B signed on June 16, 2014 with respect to the shares of 2/9 among the real estate listed in the attached list.

1. Basic facts

A. As of August 29, 2016, the head of the regional tax office and Samsung C&T under the Plaintiff’s control have national tax claim regarding B, including transfer income tax of KRW 581,202,540, as follows:

B. The deceased C (hereinafter “the deceased”) died on June 16, 2014, and the Defendant, the wife of the deceased, and his/her children, B, D, and E jointly inherited the deceased.

C. The Deceased owned the real estate indicated in the separate sheet (hereinafter “instant real estate”). On June 16, 2014, the Defendant, the co-inheritors of the Deceased, and the Defendant, B, D, and E, who owned the instant real estate solely (hereinafter “instant agreement on the division of inherited property”).

Accordingly, on July 23, 2014, the registration of transfer of ownership in the name of the defendant was completed on the ground of the agreement on the division of inherited property in this case.

On the other hand, at the time of the agreement on division of the inherited property in this case, B owned positive and negative properties as listed below, and was in excess of obligations.

F GHIF / without dispute, Gap evidence Nos. 1, 3 through 7 (including paper numbers) and the purport of the whole pleadings

2. Determination on the defense prior to the merits

A. On July 23, 2014, the gist of the defense, the Defendant completed the registration of ownership transfer on the instant real estate, and the competent registry office immediately notified the Plaintiff of the details thereof. As such, on July 23, 2014, the Plaintiff was aware of the fact that the Defendant completed the registration of ownership transfer on the instant real estate due to the division of inherited property agreement and that B renounced the inheritance share on the instant real estate due to the division of inherited property agreement.

The instant lawsuit is unlawful as it was filed after the lapse of the exclusion period of one year thereafter.

B. According to the Defendant’s assertion, even if the content on the registration of ownership transfer among private persons is notified to the competent tax office, the registration of ownership transfer under the Defendant’s name will be completed.