1. The Defendant’s transfer income tax for the Plaintiff on April 10, 2015, KRW 35,644,534, and securities transaction tax for the Plaintiff on April 10, 2015.

1. Details of the disposition;

A. The Plaintiff is the father of C, who has been working as the representative director of the instant company since December 31, 2006, as a shareholder of B (hereinafter “instant company”) for the main purpose of the design, waterproof construction business, etc. established on December 10, 1993.

B. The statement of changes in stocks, etc. submitted by the instant company at the time of filing a corporate tax return for the business year 2010 states that the total amount of 25,246 shares of the instant company was transferred from the Plaintiff, D, and E during the pertinent business year to the Plaintiff, D, and seven officers and employees of the said company (hereinafter “C et al.”).

(hereinafter) 6,211 shares transferred from the Plaintiff to C (hereinafter “instant shares”). / [the Table] 2,115 shares E2,15 shares F2,920 shares D 16,920 shares G 4,935 shares 3,525 shares H 2,115 shares I 12,15 shares J 1,410 shares C 1,410 shares 1,410 shares C 6,211 shares total of 25,246 shares,25,246 shares total of 25,246 shares

C. From May 6, 2013 to June 19, 2013, the head of Samsung District Tax Office conducted a consolidated investigation with respect to the instant company, and deemed that C and seven others were gratuitously donated 25,246 shares of the instant company from the Plaintiff, D, and E on December 14, 2010, and notified the tax office having jurisdiction over the address of C and seven others of the taxation data.

Accordingly, the head of the competent tax office of C assessed the value of the instant shares as KRW 47,907 per share according to the supplementary assessment method under the Inheritance Tax and Gift Tax Act, and assessed KRW 73,746,750 per share on September 2, 2013 on the instant shares transferred from the Plaintiff to C, and imposed KRW 9,89,280 per share on KRW 1,410 per share transferred from D.

C and seven others were dissatisfied with the imposition of gift tax, and filed an appeal with the Tax Tribunal on October 30, 2013. On April 28, 2014, the Tax Tribunal re-examineed whether C acquired 25,246 shares, including the shares in this case, for consideration by the Plaintiff, etc. and based on the results.