1. The judgment of the court of first instance is modified as follows.

In August 21, 2017, the gift tax attributed to the Plaintiff in 2012, which was paid by the Defendant on August 21, 2017.

1. The grounds for admitting the judgment of the court of first instance are the same as the grounds for the judgment of the court of first instance, except for dismissal or addition as the judgment of the court of first instance 2. Thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. As to the part to be dismissed or added, the second 14 pages of the judgment of the court of first instance shall be “ September 26, 2018” and “ March 12, 2018.”

The two pages of the judgment of the court of first instance (hereinafter “the same”) are as follows: (a) each description of the said 17 line, and the purport of the entire pleadings. The fourth 15 line of the judgment of the court of first instance is not more than 15 lines as follows. (b) Determination as to the assertion of violation of the underlying taxation principle is made; and (c) Determination as to the assertion of violation of the underlying taxation principle, the following facts are acknowledged in light of the purport of Gap’s 2, 4, 6, and Eul’s 1 through 6 evidence; and witness E’s testimony

D is the mother of E, and the plaintiff is the wife of the wife of E.

The name before the plaintiff's opening is H.

At the time of the establishment of the instant corporation, D stated that “it shall be memory as South Korea,” with respect to the funds for stock acquisition at the time of tax investigation.

On the contrary, E stated to the effect that “The capital amount of 500 million won required for the establishment of the instant legal entity was lent to D” at the time of tax investigation and in this court, respectively.

At the time of the tax investigation, the Plaintiff stated that “The instant shares were acquired from E, and the acquisition price was borrowed from E.”

The financial data related to this was not submitted.

The office of the instant legal entity is located in Gangdong-gu Seoul Metropolitan Government I and J, and there is a pharmacy operated by the E wife.

E is a holder of the said J-1/2 equity and a lessor of the said office.

The Plaintiff was the only internal director of the instant legal entity from May 24, 2012 to June 11, 2014.

The plaintiff stated that he did not properly associate with the process, period, remuneration, etc. of his position as above, and the contents related to the business of the corporation of this case, such as the client and the trader.