1. Revocation of a judgment of the first instance;

2. The instant lawsuit shall be dismissed.

3. The total costs of the lawsuit shall be borne by the defendant.

1. Details of the disposition;

A. On May 22, 2009, the Plaintiff joined a non-listed corporation B (hereinafter “B”) and has been in charge of promoting and selling products.

B. B, following the resolution of the board of directors on April 27, 2010, issued new shares 15,000 shares that constitute 10,000 shares (hereinafter “instant subscription for new shares”) and based on B’s list of shareholders, the current status of shareholders’ composition and shares before and after the implementation of the instant subscription for new shares is as listed in the following table.

The number of non-high number of shares (%) 2,500 50 12,500 60 - 30 2,000 - 1,500 - 1,000 - 20 1,000 - 1,000 20 1,000 - 20 1,000 2,0000 10 (C’s - 00 00 - 2,0000 - 0 0 - 2,000 1,000 - 0 0 - 0 1,000 - 0 1,000 - 0 0 1,000 5,000 -

C. On May 7, 2013, the Defendant imposed an additional tax on the Plaintiff pursuant to Article 39(1)1(a) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 2011); Article 29(3)1(a) and Article 54 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 23591, Feb. 2, 2012); on the ground that “The Plaintiff acquired profits by acquiring 2,00 shares of the forfeited shares (hereinafter “instant shares”) out of 6,00 shares that occurred from the waiver of the preemptive rights to new shares during the capital increase process of the instant case by a third party, including KRW 324,319,00, KRW 16,150, KRW 150, KRW 380, KRW 150, KRW 4805, KRW 306,5085,06).

(hereinafter “instant disposition”) D.

On September 16, 2013, the Plaintiff filed a petition for a trial with the Tax Tribunal on September 16, 2013, but was dismissed on February 24, 2013.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1, 8, 9, 14 through 17, and Eul evidence No. 1, respectively.