1. The plaintiff's claim is dismissed.

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

Details of the disposition

On August 29, 2011, the Plaintiff received 2,000 shares of the instant company from the representative director C of the non-listed corporation B (hereinafter “instant company”) on May 1, 201, the Plaintiff reported and paid KRW 900,000,000, under the premise that the appraised value per share of the instant shares is KRW 5,000, at the time of donation.

From July 26, 2011 to September 23, 2011, the head of the Gu-ro Tax Office corrected corporate tax for the business year 2010 of the instant company on the grounds of the omission of the report of the general corporate tax amounting to KRW 2,505,00,00, which was conducted with respect to the instant company from July 26, 201 to September 23, 201, and confirmed that the assessed value per share of the instant shares based on the supplementary assessment method prescribed by the Inheritance Tax and Gift Tax Act was KRW 754,281 and notified the Defendant thereof.

Accordingly, on November 9, 2016, on the premise that the assessment value per share of the instant shares at the time of the donation was KRW 754,281, the Defendant corrected and notified the Plaintiff of the gift tax amounting to KRW 689,430,560 (including additional tax) of the instant shares.

(hereinafter “instant disposition”). The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal following the procedure of filing an objection, but the appeal was dismissed on September 8, 2017.

[Grounds for recognition] The facts without dispute, Gap evidence Nos. 1, 3 and Eul evidence Nos. 1, 2, 4, and 5 (including serial numbers; hereinafter the same shall apply), and the purport of the entire pleadings as to whether the disposition of this case is legitimate, the plaintiff's assertion that the disposition of this case is legitimate, is not the donation of the shares of this case, but the acquisition of the shares of this case by Eul as consideration for the transfer of D's operating rights or for the provision of labor operated by the plaintiff while entering the company of this case, and the date of acquisition of the shares of this case is also October 2010. Thus, the disposition of this case on the ground that the plaintiff received a donation of the shares of this case

Facts of recognition

(e).