1. Disposition imposing gift tax of KRW 364,454,140 on the portion of gift on December 17, 2012, the Defendant imposed on the Plaintiff on April 1, 2016, and imposition of KRW 124.

1. Details of the disposition;

A. C, who had been employed by B (hereinafter “B”), transferred 130,200 shares of B (54.25% equity) to the Plaintiff, who had been employed by B as the employee of B (the title was in charge of the representative director), to KRW 5,500 per share. The Plaintiff acquired 63,200 shares from C on April 2010, and paid KRW 347,60,000 shares (=5,500 x 63,200 shares x 67,00 shares). ② around December 2012, the Plaintiff paid KRW 368,50,000 shares (5,500 x 67,500 shares).

Pursuant to Article 60(1) and (2) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Jan. 1, 2013; hereinafter “former Inheritance Tax Act”) and Article 49(1) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 24358, Feb. 15, 2013; hereinafter “Enforcement Decree of the former Inheritance Tax Act”), since non-specially related persons purchased B stocks from C on April 30, 2010, KRW 5,500 per share, the market price of B stocks at the time of acquisition can be deemed as KRW 5,50 per share. Accordingly, the first sales contract cannot be deemed as KRW 20 per share, which is the base date for appraisal, and thus, the market price at the time of acquisition of stocks cannot be assessed pursuant to Article 60(1) and (3) of the former Enforcement Decree of the Tax Act as the market price at the time of acquisition by transfer by transfer by transfer by transfer by transfer by transfer by transfer by transfer by transfer.

B. As a result of the Commissioner of Busan Regional Tax Office’s tax investigation conducted against the Plaintiff from September 2015 to December 2015, 2015, the Plaintiff’s purchase of B shares 130,200 shares from C is “the first sales contract for B shares” (hereinafter “the first sales contract”).