1. The plaintiff's claim is dismissed.

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

1. During the disposition process, the shareholders C, D, E, and F of Company B (hereinafter “stock company”) entered into a contract for acquisition of shares and management rights with G on January 15, 2009 (hereinafter “G”).

(hereinafter “this case’s acquisition of shares”. The content of B’s total outstanding shares 310,000 shares, transferred to G a total of KRW 15 billion (6,225 won per share) of KRW 15 billion (66,225 won per share) and granted a claim to sell shares to G with respect to the remaining shares of KRW 83,500 shares owned by F and new shares of KRW 3 billion that are to be underwritten by B.

Accordingly, on March 28, 2009, F acquired B's new shares 45,300 shares by converting B's loan claim of KRW 3 billion to investments, and G acquired B's new shares 60,400 shares by participating in B's new shares increase with capital increase on April 9, 2009.

On May 6, 2009, the Plaintiff sold 145,700 shares of H (B’s trade name was changed to H on April 22, 2009) to KRW 9,648,982,00, and on May 24, 2010, the Plaintiff reported and paid KRW 657,639,000 capital gains tax by applying Article 94(1)3 (b) of the Income Tax Act to the transfer of Plaintiff’s shares to the Defendant by applying Article 94(1)3 (b) of the Income Tax Act to the transfer of Plaintiff’s shares.

On the other hand, H reduced the capital of KRW 835 million by the method of reduction of capital on June 13, 2011, with a view to reducing the capital of KRW 835 million, on July 15, 2011, H reduced the capital of KRW 83,500,000 per share of KRW 28,800 per share; H sold the remaining shares of KRW 45,300 on June 7, 2011, KRW 45,530 on June 7, 201, KRW 40,70 on July 15, 201, KRW 71 to KRW 3,000 per share and KRW 28,800 on October 20, 201.

Accordingly, the Defendant is aware that 83,500 shares out of H shares owned by F were actually transferred at the time of transfer of the Plaintiff’s shares, and on the ground that the transfer of the Plaintiff’s shares constitutes the transfer of specific shares under Article 94(1)4(c) of the Income Tax Act, the Plaintiff on December 1, 2012.