1. The Defendant’s imposition of gift tax of KRW 312,691,880 against the Plaintiff on June 3, 2011 exceeds KRW 285,492,643.

1. Details of the disposition;

A. The unlisted company B Co., Ltd. (hereinafter “instant company”) was established on December 1, 199, and C, one of the promoters of the instant company, acquired 2,000 shares out of 10,000 shares of the instant company on December 1, 1999, and acquired 2,000 shares of the instant company from D on December 20, 201.

B. The Plaintiff acquired 40,000 shares of the instant company (hereinafter “instant shares”) owned by the Plaintiff from the Plaintiff, the largest shareholder of the instant company, from C, to KRW 40,000 (i.e., KRW 10,000 per share x 4,000 shares) and paid KRW 40,000 to C on February 28, 2006. The Plaintiff transferred the instant shares to the Plaintiff on March 31, 2006.

C. From March 14, 2011 to April 22, 2011, Busan regional tax office conducted a tax investigation on the stock fluctuation, etc. of the instant company. As a result, as of March 31, 2006, the Plaintiff evaluated the market price of the instant shares as indicated below as KRW 284,860 per share (the Plaintiff asserted that the total sales claims against 10 companies, such as Gelim General Construction Co., Ltd., 19,200 won, total sales claims of KRW 618,959,200, among the sales claims of the instant company at the time of the investigation, the Busan regional tax office claimed that the total sales claims against 10 companies, such as Gelim General Construction Co., Ltd., Samsung & Samsung Construction Co., Ltd., Ltd., and ASEAN Co., Ltd., Ltd., 103,518,400 won per share under the former Inheritance Tax and Gift Tax Act (amended by Act No. 9400, Mar. 16, 2009).