1. The Defendant’s disposition imposing gift tax amounting to KRW 389,448,640, which was imposed on the Plaintiff on February 2, 2015, shall be revoked.

2. The costs of lawsuit shall be.

1. Details of the disposition;

A. On December 26, 2012, the Plaintiff did not report capital gains tax even though 10,000 shares of Company B (hereinafter “B”) which were registered in its own name on the register of shareholders were transferred to Korea Securities Finance Corporation due to enforcement of the pledge right, and was subject to tax investigation by the Defendant on capital gains tax, etc.

B. The Defendant determined that the beneficial shareholder B’s shares 10,000 shares of the above B was the Plaintiff-friendly job offer C, and determined on December 16, 2002 that the Plaintiff paid 7,000 shares B from C to 10% of the total number of shares issued B at that time, and the Plaintiff included 30,000 shares free of charge on December 19, 2012, and the Plaintiff’s shares B were 10,000 shares in the Plaintiff’s name (the total number of shares issued was 3,000 shares increased by 3,00 shares, and 10,000 shares in the Plaintiff’s name were 10,00 shares in the title trust. In addition, by applying Article 41-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 6780, Dec. 18, 202; hereinafter referred to as “Evidence Tax Act”) to the Plaintiff on February 38, 2014

(hereinafter “instant disposition”). C.

On July 13, 2015, the Plaintiff appealed and filed a tax appeal with the Tax Tribunal on May 1, 2015, but was dismissed on December 23, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence No. 1, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) heard that it is necessary to divide B shares against listing from C in around 2002, and paid C the price of KRW 175 million per share (250 million per share) to purchase the instant shares. Therefore, the instant disposition based on the premise that the Plaintiff is a title trustee of the instant shares is unlawful. 2) Even if the Plaintiff was deemed to have received title trust of the instant shares from C, it was merely for the purpose of allocating B’s shares for listing, and it is possible to avoid or avoid taxes imposed by C.