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 is a shareholder who, around August 2013, was the controlling shareholder C (40.1% of the outstanding shares B as of March 31, 2006 to March 1, 2012; and D is a shareholder who, as the representative director of B; and from March 2, 2012 to July 29, 2014, held 110,894 shares (13.86% of the shares) of B owned by each person who worked as the auditor of B during the period from March 31, 206 to March 1, 2012.

B. On August 2, 2013, the Plaintiff acquired B shares of KRW 22,000 per share from D (hereinafter “instant shares”) in total of KRW 176,00,000 per share.

(hereinafter “instant transaction”). C.

Based on Article 60(3) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 12168, Jan. 1, 2014; hereinafter “Inheritance Tax Act”) and Articles 54 through 56 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 24697, Aug. 27, 2013; hereinafter “Enforcement Decree”), the Defendant calculated the price per share of the instant shares by the supplementary assessment methods, and determined that the Plaintiff acquired the instant shares from a specially related person at a price lower than the market price.

Accordingly, the Defendant determined and notified KRW 225,03,652,00,00 as gift tax on November 14, 2016, by deeming the difference between the related parties under Article 35(1) of the Inheritance and Gift Tax Act (i.e., KRW 53,166 x 22,000) and KRW 176,00,000 as transaction price (= KRW 8,000 x 22,000) less KRW 3,00,000,000 as gift tax (i.e., KRW 93,652,000 as gift tax).

(hereinafter “instant disposition”). A.

On March 3, 2017, the Plaintiff appealed against the instant disposition and filed an appeal with the Tax Tribunal. However, the Tax Tribunal dismissed the Plaintiff’s appeal on June 12, 2017.

[Ground of recognition] Facts without dispute, Gap evidence 1, 3, and 8, Eul evidence 1 (including branch numbers; hereinafter the same shall apply), and arguments.