1. The Defendant’s disposition imposing gift tax amounting to KRW 989,867,130, which was imposed on the Plaintiff on January 9, 2014, is revoked.

2. The costs of lawsuit shall be.

1. Details of the disposition;

A. On June 28, 2009, the Plaintiff acquired 57,000 shares of C (hereinafter “C”) from B (hereinafter “C”) in KRW 500 per share.

B. On January 9, 2014, the Defendant issued a disposition imposing gift tax amounting to KRW 989,867,130 (including additional tax) on the ground that the Plaintiff acquired the instant shares of KRW 500 per share, a low-price of KRW 39,000 per share (hereinafter “instant disposition”).

C. On March 18, 2014, the Plaintiff appealed and requested an inquiry to the Tax Tribunal, but was dismissed on September 2, 2014.

【Ground of recognition】 The fact that there has been no dispute, Gap evidence 5, Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. In rendering the instant disposition, the Plaintiff’s assertion can not be deemed as the market price at the price formed by transaction example, 39,000 won, which was understood as the market price per share of C in the instant disposition. The Plaintiff could not easily understand the objective value because the possibility of listing C shares at the time of the Plaintiff’s acquisition of the instant shares was unclear, and it cannot be deemed that the Plaintiff acquired the instant shares at a price significantly lower than the market price without justifiable grounds under the transactional practice.

(b) Entry in the attached Form of relevant Acts and subordinate statutes;

C. Article 35(2) of the Inheritance Tax and Gift Tax Act provides that, where a person, other than a related party, takes over property between the parties, without any justifiable reason, the amount equivalent to the difference between the price and the market price shall be presumed to have been donated, and the amount equivalent to the profits prescribed by the Presidential Decree shall be deemed to be the value of donated property to the person who acquired the profits.