1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On December 24, 2012, the Plaintiff acquired 3,000 non-listed shares (hereinafter “instant shares”) of the amount of KRW 10,000 per share of the amount of the non-listed shares in the amount of Maritime Affairs and Fisheries Co., Ltd. (hereinafter “Maritime Affairs and Fisheries”).

B. The Commissioner of Busan Regional Tax Office, through a planning and inspection, conducted a reduction of capital of non-listed stocks, etc., notified the Defendant of the taxation data that the transaction value of the instant stocks acquired by the Plaintiff is subject to gift tax on the gift accrued from a low-price transfer. Accordingly, the Defendant calculated the net value of the instant stocks by applying Article 54 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 24358, Feb. 15, 2013; hereinafter “Enforcement Decree of the Inheritance Tax and Gift Tax Act”) by weighted average of 175,619 won in the ratio of 3:2, and then assessed the net value of the instant stocks at 175,619 won in accordance with Article 35 of the Inheritance Tax and Gift Tax Act (amended by Act No. 11609, Jan. 1, 203; hereinafter “Premium Tax Act”) and Article 26 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act (30 million won x 1000,3008 won in the basic tax base amount, 40000.7.80

(hereinafter “instant disposition”). C.

The plaintiff appealed and filed an appeal with the Tax Tribunal, but was dismissed on January 22, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence No. 1-1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Defendant alleged the Plaintiff’s assertion: (a) assessed the appraised value per share of the shares of marine farmers and fishermen by the weighted average ratio of net asset value and net profit and loss value; (b) however, marine farmers and fishermen assessed the assessed value per share on July 23, 2010 during the period from the date of commencing the business year in which the third anniversary before the base date of appraisal falls to the base date of assessment.