The demand for a lawsuit that has not gone through the appeal procedure is unlawful.

Since the Plaintiff did not go through the procedures of appeal, such as a request for review or a request for adjudication, even after receiving a disposition of refusal after the payment of gift tax or a request for correction.

Article 45-5 of the Inheritance Tax and Gift Tax Act

2014Guhap73463 Revocation of Disposition of Imposition of Gift Tax

AA

BB Director of the Tax Office

June 19, 2015

July 3, 2015

1. The instant lawsuit shall be dismissed.

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

Cheong-gu Office

The defendant's rejection disposition of correction of KRW 0,000,000 against the plaintiff on June 25, 2014 is revoked.

(In doing so, the purport of the plaintiff's claim is examined).

1. Details of the disposition;

A. On July 31, 2013, the Plaintiff reported the profit deemed donated through the transaction with the specially related corporation, and paid KRW 0,000,000 as gift tax.

B. On May 2, 2014, the Plaintiff filed a claim for rectification that the gift tax returned and paid to the Defendant as above was refunded, but the Defendant rejected it on June 25, 2014.

[Ground of recognition] Facts without dispute, entry of Gap evidence 1 to 3, purport of the whole pleadings

2. Whether the lawsuit of this case is lawful

In order to file an administrative suit against a disposition imposing national taxes, a request for examination or a request for trial and a decision thereon shall be made within the prescribed period under the Framework Act on National Taxes (Articles 55 and 56 of the Framework Act on National Taxes). The plaintiff does not go through the procedure of objection, such as a request for examination or a request for correction, within the prescribed period, even after having received the payment of gift tax or the

3. Conclusion

If so, the plaintiff's lawsuit of this case is unlawful and dismissed, and it is so decided as per Disposition.