1. The Defendant’s gift tax amounting to KRW 1,244,935,850 (including penalty tax) for the Plaintiff on September 4, 2014.

1. Details of the disposition;

A. From April 21, 2014 to July 25, 2014, the director of the Seoul Regional Tax Office conducted the consolidated investigation of corporate tax and the investigation of changes in shares against the non-party B Co., Ltd. (hereinafter “non-party B”). As a result, on September 24, 2004, the Plaintiff, who is the representative director of the said company, verified the title trust (hereinafter “instant shares”) with the non-party C, a Chinese citizen, and notified the Defendant of the title trust (hereinafter “instant title trust”).

B. Accordingly, on September 4, 2014, the Defendant: (a) designated the title truster who falls under the donor as a joint obligor pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “Gift”); and (b) determined and notified the Plaintiff of KRW 1,244,935,850 (including additional tax) of the gift tax for 2004 on the same day as a joint obligor pursuant to Article 4(5) of the same Act.

(hereinafter “instant disposition”). C.

The Plaintiff appealed and filed a request for examination with the Commissioner of the National Tax Service on December 10, 2014, but the said request for examination was dismissed on March 10, 2015.

【Ground of recognition】 The fact that there has been no dispute, Gap Nos. 1, 2, Eul Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff asserted that the Plaintiff merely held the shares of the non-party company C in title trust so that C may obtain the status of stay for corporate investment (D-8) under the Immigration Control Act. The instant disposition, based on the premise that C did not have any tax avoidance purpose in the instant title trust, even though it did not have any tax avoidance purpose in the instant title trust, is unlawful.

(b) Entry in the attached Form of relevant Acts and subordinate statutes;

C. The plaintiff owned 10,00 shares issued by the non-party company at the time of February 4, 1994. However, the plaintiff owned 10,00 shares issued by the non-party company (Law No. 5053 of Dec. 29, 1995).