1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On January 3, 2012, the Plaintiff, the father of the Plaintiff, donated 190,876 shares in the non-listed shares of C (hereinafter “Non-Party Corporation”) from B (hereinafter “Non-Party Corporation”) and held 236,352 shares (52%) out of the total number of shares issued by Non-Party Corporation 454,52 shares. From August 30, 2013, the Plaintiff served as the representative director of Non-Party Corporation from August 30, 2013.

B. On the other hand, on April 30, 2012, the Plaintiff reported and paid KRW 249,99,800, gift tax calculated by deducting KRW 500 million from the taxable value of the gift tax on the instant shares from the taxable value of the gift tax pursuant to Article 30-6(1) of the former Restriction of Special Taxation Act (amended by Act No. 12173, Jan. 1, 2014; hereinafter “former Restriction of Special Taxation Act”) to the Defendant regarding the donation of the instant shares.

C. After that, on June 30, 2014, the Seoul Central District Court obtained the rehabilitation plan approval (Seoul Central District Court 2013 hap277) from the Seoul Central District Court, and according to the above approval decision, a consolidation of shares, issuance of new shares following debt-equity swap, and consolidation of shares was conducted. Accordingly, the number of shares of the non-party corporation owned by the Plaintiff was reduced to 40,377 shares (17% of the total number of issued shares).

On February 1, 2016, the Defendant confirmed that the number of shares and shares of the non-party corporation donated to the Plaintiff, as seen above, have decreased. On August 1, 2016, the Defendant determined and notified the Plaintiff of KRW 1,458,474,870 based on the gift of the instant shares in accordance with the said provision, deeming that the Plaintiff’s act of imposing gift tax pursuant to Article 30-6(2)2 of the former Restriction of Special Taxation Act constitutes “the case where the shares of the donated shares are reduced.”

(hereinafter “instant disposition”) e.

The Plaintiff appealed against the instant disposition and filed a request for examination with the Commissioner of the National Tax Service. However, the Commissioner of the National Tax Service on December 14, 2017.