1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. On December 1, 2004, the Plaintiffs received 3,000 shares issued by the non-party company that was the unlisted company at the time from D, the largest shareholder of the non-party company, as the employee of the non-party company C (hereinafter “non-party company”); and on December 8, 2004, the Plaintiff A donated 3,00 shares issued by the non-party company that was the non-party company at the time (hereinafter “the non-party company shares”).

B. On December 22, 2005, Nonparty Company offered new shares with capital increase, and the Plaintiffs acquired each of 750 shares (hereinafter “instant new shares”) that they own at KRW 5,000 per share with respect to the above new shares issued with capital increase.

After that, the shares of the non-party company were listed on January 25, 2008 to the KOSDAQ market.

C. The Busan regional tax office conducted an integrated investigation with respect to the non-party company from August 10, 2009 to September 30, 2009, and imposed gift tax on the Plaintiffs on the profits accrued from listing 3,000 shares originally issued. However, gift tax was not imposed on the profits accrued from listing the new shares with compensation in this case.

On January 25, 2010, the Board of Audit and Inspection issued a request to audit the business affairs of the Busan Regional Tax Office to levy KRW 105,00,000,00 for each of the plaintiffs' interest based on the listing of the instant new stocks for consideration. On July 5, 2010, the Defendant imposed the gift tax of KRW 29,647,80 (including additional tax of KRW 28,298,174) on each of the plaintiffs as the value of donated property with the listed gains as the value of donated property.

(hereinafter “each disposition of this case”). (e)

The Plaintiffs were dissatisfied with each of the dispositions in this case and filed an appeal with the Tax Tribunal on September 17, 2010, but the Tax Tribunal dismissed the appeal on June 30, 201.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2 (including virtual number; hereinafter the same shall apply), Eul evidence 1 to 5, the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The plaintiffs' assertion that the listed profits from the shares issued with 1 capital increase are not subject to gift tax. ① The wording of Article 41-3(6) of the Inheritance and Gift Tax Act is Paragraph (1).