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 October 15, 201, the Plaintiff transferred 150,000 shares of B Co., Ltd. (established as C Co., Ltd. on January 9, 1996 and changed to the trade name as of May 10, 2001; hereinafter “B”) under the name of the Plaintiff.

B. On August 3, 2015, the Defendant: (a) deemed that “the Plaintiff received the said shares from D, the father, around October 15, 2011; and (b) calculated KRW 877,500,000, the average of the closing price of the Plaintiff’s father, as the value of donated property for two months before and after the date, as the value of donated property, and imposed KRW 307,517,170 on the Plaintiff.

(hereinafter “instant disposition”). C.

On August 10, 2015, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the said request on May 19, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1, 2 and 5, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion does not mean that the Plaintiff received the said shares from Stockholm options in return for joint efforts with D, but is presumed to have received only 5,000 shares out of 10,000 shares, as the contribution rate was presumed to have been 5:5,00 shares, and even in the time and value of the donation, the Plaintiff received shares on November 20, 2006. Therefore, the gift tax should be calculated on the basis of KRW 50,000,000, which is the face value of shares at the time of the donation.

Nevertheless, the Defendant deemed October 15, 201, which was the time when the transfer was made in the name of the Plaintiff, as the time of donation, and calculated the value of donated property at KRW 877,500,000 and imposed gift tax accordingly, the instant disposition is unlawful.

(b) as shown in the attached Form of the relevant statutes;

C. The facts of recognition 1D, between December 6, 2002 and January 2, 2003, 2003, "B" shall grant D the right to exercise the Stockholm options to only 10,000 shares of B after the end of the year in which the sales, including the heating projects and automation-related projects, are achieved in the amount of KRW 3 billion, and the sales are achieved after the end of the year in which the sales are achieved in the amount of KRW 7 billion.