1. The Defendant imposed a gift tax of KRW 20,603,600 on the Plaintiff on January 31, 2012, which was imposed by the Plaintiff on March 6, 2015, KRW 13,322.

1. Details of the disposition;

A. As a result of the Seoul Regional Tax Office’s investigation into the source of funds against the Plaintiff from October 2, 2014 to January 6, 2015, approximately KRW 1.6 billion of the insurance premium out of the Plaintiff’s property is not verified. According to the process of paying the insurance premium, the insurance premium at issue 1 as shown in the following table was deposited from the Plaintiff’s new bank account at B (the Plaintiff’s father). The insurance premium at issue 2 was deposited from the B’s account, the Plaintiff, C (the Plaintiff’s spouse), D (the Plaintiff’s spouse’s spouse’s spouse), and E (D’s spouse), and the insurance premium at issue 3 was deposited from the B’s scloid bank account in the name of B, and the insurance premium was paid from the Plaintiff’s account in the name of the Plaintiff’s management of the revenue of the Fel operated by B, and the Defendant notified the Defendant of such taxation data.

The major issue insurance premium is the Plaintiff’s insurance account amount for the Plaintiff’s insurance premium claim for the insurance premium of 1 insurance premium (H), one life (G), 741,450,00 donation, and 2 insurance premium of 793,422,90 donation non-recognized 3 insurance premium of 87,835,979-4 insurance premium of 92,778,753 total 1,615,487,632,632 of the 2 insurance premium non-recognized 3 insurance premium non-recognized-4 insurance premium of 92,78,753 donation (J, et al. 24)

B. The Defendant deemed that the instant insurance premium was donated to the Plaintiff, and on March 6, 2015, determined and notified gift tax of KRW 783,561,410 in total, as indicated in the attached Form, to the Plaintiff (hereinafter “instant disposition”).

C. The Plaintiff filed an appeal with the Tax Tribunal on September 8, 2015 upon filing an objection on May 15, 2015, but the Tax Tribunal dismissed the appeal on November 25, 2015.

[Reasons for Recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1 (including each number), the purport of the whole pleadings

2. Determination on the lawfulness of the instant disposition

A. The summary of the Plaintiff’s assertion 1-2 insurance premium is not paid out of the accounts in the name of B, the Plaintiff, C, D, and E, but paid out.