1. The Plaintiff (Counterclaim Defendant) paid KRW 34,229,353 to the Defendant (Counterclaim Plaintiff) and its related amount from August 12, 2016 to February 10, 2017.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On December 27, 2010, the Plaintiff, who donated real estate, received 102 houses for multi-household 102 and 16 real estate in Dongjak-gu Seoul Metropolitan Government from Non-Party C and completed the registration of ownership transfer.

(hereinafter “instant donation”). (b)

(1) On March 31, 201, the Plaintiff reported the tax base of KRW 1,180,549,520 to KRW 1,150,549,520 on the gift of this case, and voluntarily paid KRW 270,197,828 on the gift tax. (2) On October 2013, the head of the Dongjak District Tax Office omitted other property donated by the same person and omitted it; (3) reported the gift tax investigation on the Plaintiff on November 20, 2013; (486,586,026 on the gift of this case; (486,506,50,300,500,500,500,500,500,50,500,000 on the gift tax of this case to the Plaintiff on November 30, 2013 (e.g., notified tax amount).

3) The Plaintiff raised an objection against the above decision, and the head of Dongjak Tax Office shall conduct the second tax investigation (hereinafter “instant tax investigation”).

C. On June 9, 2014, the Plaintiff entered into a delegation contract with the Defendant and Nonparty E regarding the instant tax investigation-related affairs (hereinafter “instant delegation contract”) with the following content:

B Around that time, each of the Defendant paid KRW 10,000,000 to the Defendant, and again paid KRW 20,000,000 on July 17, 2014.

At the time of the conclusion of the instant delegation contract, the Plaintiff set the direction of delegation by proving that the instant donation was an onerous donation in order to reduce the amount of gift tax, and in that case, was aware that the gift tax was imposed on the donor, and may be imposed on C.