Suwon District Court 201Guhap1512 (02.01)

early 2010 Heavy0363 ( November 02, 2010)

title trust for the purpose of tax avoidance

(As in the judgment of the court of first instance), regardless of the payment of the purchase price, a contract for stock transfer and concession that allows the plaintiff to exercise the preferential right to purchase with respect to the plaintiff is prepared, and the plaintiff is not a shareholder who exercises the right to the shares of this case, and thus constitutes a title trust for the purpose of tax avoidance.

2012Nu946 Revocation of Disposition of Imposition of Gift Tax

SAA

Head of Central Tax Office

Suwon District Court Decision 201Guhap1512 Decided February 1, 2012

September 20, 2012

September 27, 2012

1. The plaintiff's appeal is dismissed.

2. Of the appeal costs, the part arising between the Plaintiff and the Defendant is assessed against the Intervenor, respectively.

The judgment of the first instance shall be revoked. The defendant shall revoke the disposition of imposition of gift tax of KRW 000 against the plaintiff on October 1, 2009.

The reasons for the judgment of the court of first instance are reasonable, and they are quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act. The plaintiff's appeal is dismissed for lack of reason