1. The plaintiff's claim is dismissed.

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

1. On July 2, 2015, the Plaintiff purchased 30,000 shares of C Co., Ltd. (hereinafter referred to as “C”) (hereinafter referred to as “instant shares”) (hereinafter referred to as “instant shares”) that are non-listed shares from B, who is not a person with a special relationship, to KRW 400,000 per share (13,333 won per share).

Considering that it is difficult to calculate the market price of the instant shares, the Defendant assessed the price per share of the instant shares as KRW 76,659 by applying the supplementary evaluation method pursuant to Articles 60(3) and 63(1)1(c) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter referred to as “Gift”), and accordingly, deemed that the Plaintiff’s acquisition of the instant shares without justifiable cause constitutes a case where the Plaintiff took over the instant shares at a price significantly lower than the market price under Article 35(2) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 201; hereinafter referred to as “ordinaryly paid additional tax”) and accordingly, included the amount of KRW 1,59,70,00 (2), 76,659, 300,000,000).

[Ground of recognition] Gap evidence Nos. 2, 3, Eul evidence Nos. 1 through 4, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion C’s shares did not have been previously traded as non-listed shares. At the time of the Plaintiff’s purchase of the instant shares from B, the value per share of the instant shares calculated based on the share price ratio (PER) was KRW 17,134 (C’s net profit per business year 2014 x average PER 10). At the time of the Plaintiff’s purchase of the instant shares from B, the Plaintiff was in a situation where the sports of valves and other valves manufacturers was not good at the time of the Plaintiff’s purchase of the instant shares. At the time of the Plaintiff’s purchase of the instant shares from B, B, a seller, was trying to sell the instant shares without fail, and the Plaintiff’s available funds were limited to KRW 449,00,000.