1. On December 11, 2014, the Defendant exceeds KRW 14,793,950, out of the gift tax of 26,763,780, imposed on the Plaintiff for the year 2012.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “B”) was a corporation established on February 24, 199 for the purpose of marine passenger and cargo transport business, etc. and changed the total number of issued and outstanding shares from 40,000 to 340,000 shares by offering capital increase around June 2001.

B. On December 31, 2012, the Plaintiff completed the transfer of ownership from C, D, and E with respect to 15,000 shares issued by B (hereinafter “instant shares”).

C. The director of the Seoul Regional Tax Office, upon conducting a tax investigation on B, etc. from September 15, 2014 to October 5, 2010 of the same year, deemed that B’s shares were trusted to G religious organizations established by the deceased’s head, H religious organizations (hereinafter “the instant religious organization”), and the believers of H religious organizations (hereinafter “the instant religious organization”), and notified the head of the competent tax office, including the Defendant, of the taxation data.

On December 11, 2014, the Defendant: (a) deemed, pursuant to Articles 45-2 and 63(3) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”), the title truster, as the largest shareholder holding more than 50/10 of the total number of outstanding shares B; and (b) assessed the value per share of the shares of this case as KRW 26,763,780 (including additional tax; hereinafter “instant disposition”) by adding 30% of the total number of outstanding shares of this case, the Defendant imposed gift tax of KRW 26,763,780 (including additional tax; hereinafter “instant disposition”).

E. The Plaintiff appealed to the instant disposition and filed an appeal with the Tax Tribunal, but was dismissed on May 1, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence No. 1 (including branch numbers, if any) and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1 is that the actual owner of the instant shares was not the deceased, but the Plaintiff, to escape from the limitation on the acquisition of treasury shares under the Commercial Act, and thus, tax avoidance is applicable.