1. On December 16, 2015, the Defendant imposed an inheritance tax of KRW 2,725,346,020 (including additional tax) on the Plaintiffs.

1. Details of the disposition;

A. 1) The Plaintiffs’ status 1) F is an unlisted company G Co., Ltd. (hereinafter “G”).

(1) 10,200 shares (hereinafter “instant shares”) equivalent to 51% of the total number of shares issued and outstanding.

(B) The Plaintiff was the largest shareholder, and died on March 3, 2014 (hereinafter “F”).

2) The Plaintiffs are the inheritors of the Deceased.

B. G’s sports center site and building purchase 1) G is a company H (former: I; hereinafter “H”) in a voluntary auction proceeding on December 3, 2012.

) The Gangseo-gu Seoul Metropolitan Government et al. and seven parcels and its ground buildings owned were awarded a successful bid of KRW 3.91 billion and acquired their ownership. The sports center operated by H was a sports center (hereinafter “instant sports center”).

(2) On December 2, 2012, G borrowed KRW 3.91 billion from K organization to provide a claim for the return of the said membership fee to G, or attached G’s real estate, etc. with the claim for the return of the said membership fee. (2) G borrowed KRW 3.91 billion from K organization for the purpose of establishing a site for the instant sports center and the purchase price for the building. The deceased jointly and severally guaranteed the said loan obligation (hereinafter “the instant guarantee obligation”), while providing the said loan obligation as security to Gangseo-gu Seoul Metropolitan Government L and M land owned by it.

C. On September 30, 2014, the Plaintiffs filed an application for return of inheritance tax and an application for permission for payment in kind with KRW 65,567,832,352, debt and deductible amount KRW 41,177,973,01, the taxable value of inherited property was 28,50,959,351, and the taxable value of inherited property was 10,732,634,708, and filed an application for payment in kind with the Defendant for payment in kind with KRW 2,732,634,634,634,708, among the above tax amount paid, for KRW 10,732,634,70,000, the amount of tax was 7,979,000,000.

The Plaintiffs are G’s obligations to return the membership fees of the sports center of this case at the time of filing the said inheritance tax base and tax amount.