1. The Defendant’s gift tax amounting to KRW 4,823,311,00 (including penalty tax) for the Plaintiff on January 11, 2013.

1. Details of the disposition;

A. On December 12, 2006, the Plaintiff, B, C, D, closing party, and E concluded a contract for acquisition of shares and management rights to transfer shares issued by F to G Co., Ltd. (hereinafter “G”) on a total of 3,251,652 shares (10% of the total issued shares, and 69,943 shares owned in the name of H, the Plaintiff’s wife; hereinafter “instant shares”) among the shareholders of the F Co., Ltd. (F, the unlisted company that runs a sexual stem cell business, and the Plaintiff’s transfer price among them, to 7,211,936,395 won (hereinafter “F”).

B. On December 12, 2006, I concluded a contract for acquisition of shares and management rights to transfer 56,400 shares (60% of total issued shares) issued by I (66,400 won per share) to an unlisted company that is engaged in the business of education as an unlisted company (hereinafter “I”) to a company that is engaged in the business of education.

(hereinafter referred to as “instant acquisition agreement” in relation to the shares of F. D. D.

On December 22, 2006, the Plaintiff received KRW 7,211,936,395 from G to H’s account, and accordingly paid KRW 592,747,820.

According to the supplementary method of assessment stipulated by the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828 of Dec. 31, 2007, hereinafter "the Inheritance Tax and Gift Tax Act"), the director of the Central Regional Tax Office of China and the director of the Central Tax Office of China conducted a tax investigation on G, and notified the tax authorities of the relevant taxation data by deeming that G not specially related with G purchased it at a higher price without justifiable grounds even though the shares value of F is not KRW 1,091 per share, and the shares value of I are not KRW 4,328 per share.

E. Accordingly, the defendant decides to refund the transfer income tax paid by the plaintiff.