1. The plaintiff's claim is dismissed.

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

1. On March 13, 2015, the Plaintiff purchased 80,000 shares (hereinafter “instant shares”) of C Co., Ltd. (hereinafter “C”) that are non-listed shares (hereinafter “instant shares”) from B, who is not a specially related person, to KRW 80,000 (10,000 per share price).

At the time of December 31, 2014, B owned B 9,000 shares, and D 7,00 shares, D 4,000 shares, E 5,00 shares, and F 5,00 shares, but the Plaintiff became the largest shareholder of C by purchasing the shares of this case from B as above.

Considering that it is difficult to calculate the market price of the instant shares, the Defendant assessed the value per share of the instant shares as KRW 91,643 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 “former Inheritance Tax Act”), and without justifiable cause, deemed that the Plaintiff’s acquisition of the instant shares without justifiable cause constitutes acquisition of the 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, 2015; 353,14,000 (73,14,000; 8,91,643 won); -80,000,000-30,000) as additional tax for late-payment, 2017.

[Ground of recognition] Evidence No. 10, Evidence Nos. 10, No. 1 and 2, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1B had to sell the instant shares because the Plaintiff suffered economic difficulties. However, since the instant shares were unlisted stocks, it was impossible to find the purchaser of the instant shares since they were not traded. The Plaintiff’s request made the instant shares taking into account B’s circumstances.