1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. On August 29, 2012, F Co., Ltd. (hereinafter “F”) issued 80,000 new shares (hereinafter “instant shares”) on August 29, 2012, F Co., Ltd. (hereinafter “F”) issued 80,000 shares (i.e., KRW 5,000 per share; hereinafter “instant shares”). H, a representative director of F and a shareholder of F, renounced the acquisition of the instant shares.

The instant shares were allocated to the Plaintiff, and the amount of KRW 400 million was paid from the Plaintiff’s one bank account to F’s national bank account, and the Plaintiff was registered as F’s shareholder.

B. In the process of investigating changes in stocks to F in 2012, the Central and Medium Enterprise Tax Office: (a) deemed that the instant shares were issued at a price lower than the market price to a person who is not a shareholder of the pertinent corporation; (b) calculated the value per share of the said new shares as KRW 17,566 in accordance with the supplementary evaluation method under the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”) pursuant to Article 39(1)1 of the former Inheritance Tax and Gift Tax Act.

Accordingly, a return after the deadline under the name of the plaintiff was submitted to the defendant on November 13, 2013, which was calculated as KRW 1,005,317,819 and KRW 315,685,340.

C. On August 13, 2014, the Plaintiff did not pay gift tax based on the above-mentioned return. The Defendant determined to impose KRW 335,660,830, which was corrected by adding additional additional taxes to the gift tax reported on August 13, 2014, and imposed a disposition imposing KRW 335,660,830, which was finally notified to the Plaintiff on the following grounds:

The notice of tax payment was sent to Yeongdeungpo-gu Seoul Metropolitan Government, Yeongdeungpo-gu, 109 Dong 2002 (hereinafter “instant apartment”). D.

The Plaintiff dissatisfied with the instant disposition and filed a request for examination with the Commissioner of the National Tax Service on June 26, 2015, but the Commissioner of the National Tax Service, on July 17, 2015, requests for request under Article 61(1) of the Framework Act on National Taxes.