1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “Nonindicted Company”) is a company established on September 21, 200 and engaged in food sales business, etc.

B. On September 21, 200, the Plaintiff was a representative director of the above company from the time of incorporation of the non-party company to March 18, 2014, and completed the transfer of each of the 5,200 shares issued by the non-party company on September 21, 200 as to the 5,200 shares issued by the non-party company transferred from the non-party C on August 21, 200.

(C) the aggregate of the above shares of 10,400 shares (hereinafter referred to as “index shares”).

The Defendant applied Article 41-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 6780, Dec. 18, 2002; hereinafter “former Inheritance Tax Act”) to the Plaintiff on May 1, 2015, on the ground that the Plaintiff received title trust of the shares in question from Nonparty Company D, the actual owner of the non-party company, and notified the Plaintiff of each gift tax (including additional tax) listed in attached Table 1.

(hereinafter “instant disposition”) D.

On June 19, 2015, the Plaintiff filed an appeal with the Tax Tribunal on the instant disposition, but was dismissed on December 30, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1, 3, Gap evidence 2-1 to 3, Gap evidence 4-1, 2, Eul evidence 1, Eul evidence 1-1, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion that the Plaintiff acquired the key shares by paying the share price to Nonparty Company in a normal manner and paying the share price to C, and thus, the Defendant’s disposition that deemed that the Plaintiff is a title trustee of the key shares is unlawful.

B. The details of the relevant statutes are as shown in Appendix 2 of the relevant statutes.

C. 1) The shareholder changes in the portion in which the issue is whether the title trust was made from D out of the issued shares of the non-party company are as follows.

At the time of establishment, Plaintiffs 5,200 (10%) 10,400 shares (20%) after August 21, 2002 (10%) c5,200 shares (10%) 0 E. 5.