The defendant's 2 million won and its 5% annual interest on the plaintiff from November 29, 2019 to January 12, 2021, and the following day.

1. Facts of recognition;

A. 1) On July 18, 2012, the Plaintiff, C (the Plaintiff’s model), and D (the Plaintiff’s father) completed the registration of the preservation of ownership of each 1/3 share of the Geumcheon-gu Seoul Metropolitan Government E-ground building (hereinafter “instant building”) newly constructed on July 18, 2012.

2) AD died on May 2, 2015, and the Plaintiff and C filed an inheritance tax return on November 30, 2015.

On July 18, 2012, the Plaintiff and C, the date of the new construction of the instant building, deemed that the Plaintiff and C received KRW 883,33,333, out of the construction cost of the new construction from D in advance, KRW 883,33,00,00,000, respectively, and imposed gift tax of KRW 319,519,197 on October 5, 2016.

B. On December 3, 2016, the Plaintiff and C delegated the affairs related to the imposition of gift tax to the tax-related Defendant.

(c)

1) The Defendant filed a request for review with the Tax Tribunal on behalf of the Plaintiff on behalf of the Commissioner of the National Tax Tribunal on behalf of the Plaintiff.

The Commissioner of the National Tax Service shall, on September 28, 2017, determine the tax standard and tax amount by deducting the amount equivalent to the 1/3 share of the instant building from the total sum of the value of the instant building and its site from the deposit money for the 1/3 floor and the instant building among the deposit money for the 3rd floor lease from the donated property from the gift tax amount.

“The decision was made.”

2) The head of the gold tax office ex officio reduced the gift tax amount against the Plaintiff at KRW 255,998,240 on February 2, 2018, reflecting the foregoing decision.

3) On April 19, 2018, the Tax Tribunal rendered a decision to dismiss the Plaintiff’s appeal regarding the disposition of imposition of the gift tax reduced on the basis of the reduction, and each of such decisions was served on the Defendant on April 23, 2018.

(d)

On July 24, 2018, the Plaintiff filed a lawsuit against the head of the Geumcheon Tax Office seeking revocation of the imposition of gift tax. However, on April 12, 2019, the court filed a lawsuit after the lapse of 90 days from the date on which the decision of the Tax Tribunal was served.

“The Seoul Administrative Court 2018Guhap 5109 decided to dismiss the judgment on the ground that the judgment was dismissed (the revocation of the disposition imposing gift tax). The judgment on May 8, 2019.