1. All of the plaintiffs' claims are dismissed.

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

1. Details of the disposition;

A. The Plaintiffs were E’s wife and children, the largest shareholder of D Co., Ltd. (hereinafter “D”), and upon offering capital increase on March 23, 2006, the Plaintiffs acquired 12,000 shares, and 6,000 shares, respectively, as the face value of KRW 10,00 per share, according to the share ownership ratio. Of the subscription price of the above shares, Plaintiff A donated KRW 107,000,000, KRW 38,000,000 for Plaintiff B, and KRW 35,00,000 for Plaintiff C used as financial resources.

B. As a result of the consolidated investigation of corporate tax against D, the director of the Seoul Regional Tax Office received money from E as above and paid the price for acquiring the above capital increase. Since D was listed at the KOSDAQ on August 22, 2006, the price of the stock at the time of listing is 21,400 won, and the price of November 22, 2006, after March 2006, 18,000 shares equivalent to the price of the stock (Plaintiff A10,700 shares, Plaintiff B3,800 shares, Plaintiff C3,50 shares, and hereinafter “instant shares”) were imposed under Article 41-3 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 828 of Dec. 31, 2007; hereinafter “former Inheritance Tax Act”).

On December 13, 2010, the Defendant notified the Plaintiff that the case satisfies, and accordingly, the Defendant imposed and collected KRW 2,786,377,780 (including additional tax; hereinafter the same shall apply) on the Plaintiff A, KRW 731,794,780 on the Plaintiff B, and KRW 652,084,720 on the Plaintiff C, respectively.

(hereinafter “instant disposition”). C.

The plaintiffs appealed and filed an appeal with the Tax Tribunal, but they were dismissed on June 27, 201.

[Reasons for Recognition] Facts without dispute, entry of Gap evidence 1 and 2 (including each number), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion 1 tax item under Article 41-3 of the former Inheritance and Gift Tax Act

In order to meet the case, a person who has a special relationship with the largest shareholder of the corporation.