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 April 14, 2009, the Plaintiff entered into a contract with the non-party B to acquire KRW 11,000 per share of 43,000 shares of CSS (the trade name was changed from the non-party B to the CSP broadcast of the Co., Ltd.; hereinafter “instant corporation”). The Plaintiff completed the transfer on the same day.

B. From March 12, 2012 to May 30, 2012, the Seoul Regional Tax Office conducted a tax investigation on stock change (hereinafter “instant tax investigation”) with respect to the Plaintiff and the instant corporations, etc., and discovered that the transfer or receipt of stocks pursuant to the said contract constitutes title trust. The Seoul Regional Tax Office notified the Defendant of the taxation data calculated by the Plaintiff as donated the value of 43,000 shares (hereinafter “instant shares”) at the time of transfer of title.

C. On July 10, 2012, the Defendant decided and notified the Plaintiff of KRW 105,150,740 of the gift tax attributed to April 14, 2009 on the transfer of ownership of the instant shares.

(hereinafter “instant disposition”) D.

The Plaintiff filed a tax appeal on the instant disposition, but the Tax Tribunal dismissed the appeal on November 28, 2013.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1, 2, Eul evidence 3-7, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. Even if the transfer of the Plaintiff’s assertion of title is a title trust, it was inevitable to prevent the delisting of the corporation’s KOSDAQ, and the loss from transfer occurred inevitably by setting the transfer price according to the regulations on the KOSDAQ market business and the enforcement regulations of the same regulations, and it did not have the purpose of tax avoidance. Thus, the title trust of the Plaintiff’s shares constitutes an exception to the deemed donation pursuant to Article 45-2(1)1 of the Inheritance Tax and Gift Tax Act, and thus, the instant disposition imposing gift tax on the Plaintiff is unlawful.