1.(a)

On October 10, 2012, the director of the tax office of the defendant Yongsan imposed the gift tax of 257,836,010 won on the plaintiff A in 209.

1. Details of the disposition;

A. Plaintiff A is the representative director and the largest shareholder of C Co., Ltd. (hereinafter “C”) who is an unlisted corporation that runs the housing construction project sales business, etc., and Plaintiff B is the director and the shareholder of C.

On the other hand, the plaintiff B is the kind of the plaintiff A.

B. On April 7, 199 and June 20, 2003, Plaintiff A and D entered into each of the partnership agreements and jointly operated them. However, due to the difference of business, Plaintiff A and D entered into a separate agreement with Plaintiff A on May 30, 2007 to divide the business that C was promoted on May 30, 2007.

After that, D resigned from the representative director of C on October 12, 2007, and retired from C on January 2009.

C. The director of the Seoul Regional Tax Office conducted C’s tax investigation on the change of shares in the year of 2009, and notified the Defendants, the disposition authority, of relevant materials, on the premise that C’s offering of new stocks by issuing new stocks, KRW 10,000 per share after the Plaintiffs’ offering of new stocks, was lower than KRW 27,875 per share price after the offering of new stocks, thereby under Article 39(1)1(b) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9924, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”).

Accordingly, on October 10, 2012, the director of the tax office of Yongsansan notified the Plaintiff of KRW 257,836,010 of the gift tax attributed to the Plaintiff in 2009. On October 11, 2012, the director of the tax office of Jungdong notified the Plaintiff of the correction of KRW 15,792,790 of the gift tax attributed to the Plaintiff B in 2009.

(2) The Defendants’ imposition of gift tax for the year 2009 is added to the gift tax imposition disposition of the Defendants (hereinafter “instant disposition”).

On December 17, 2012, the Plaintiffs filed an appeal against the instant disposition, but the Tax Tribunal dismissed the Plaintiffs’ appeal on April 19, 2013.

[Reasons for Recognition] Facts without dispute, Gap evidence 1-1, 2, Gap evidence 2, 3, 5, Eul evidence 1-2, and arguments.