1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff and B Co., Ltd. (hereinafter “B”) are unlisted companies for the purpose of manufacturing and selling phrases.

B. On August 31, 2009, the Plaintiff purchased B shares 29,970 shares (hereinafter “instant shares”) from C, a person with a special relationship, at KRW 117,00 per share (hereinafter “instant transaction”). D, a person with a special relationship, was donated shares of KRW 24,370 per share from C on the same day and declared gift tax as donated shares of KRW 123,098 per share.

B The details of stock changes in the year 2009 are as follows:

On December 31, 2009, changed number of shares on December 31, 2008, 122, 491, 291, 29, 2491, 24, 670, 68, 68, 151 D 83,309, 2470, 679, 029, 29,97029, 29, 97029, 329, 32, 118, 32, 118, 38,038,038,003 G5, 304, 304, 5, 304, 5, 305, 5, 307, 30749, 207, 30749, 207, 30749, 207, 30749, 2007

C. On August 31, 2009, the director of the Seoul Regional Tax Office calculated and donated B’s shares as KRW 123,098 per share to D and notified the Defendant that the difference occurred by selling the said shares to the Plaintiff at KRW 117,000 per share. Accordingly, on January 9, 2014, the Defendant notified the Plaintiff of the correction of KRW 736,123,140 on the ground that the Plaintiff purchased B’s shares at low price on the ground that “the Plaintiff purchased B’s shares from a related party C at low price.”

(hereinafter “instant disposition”) D.

The Plaintiff filed an objection against the instant disposition on March 6, 2014, but was dismissed. On June 9, 2014, the Plaintiff filed an appeal with the Director of the Tax Tribunal, but the said claim was dismissed on October 21, 2014.

[Ground of recognition] Unsatisfy, Gap evidence 1, Gap evidence 2-1, Gap evidence 3, 5, Eul evidence 1, 2.