1. The Defendant’s imposition of gift tax of KRW 347,454,330 (including additional tax) against the Plaintiff on September 1, 2014 shall be revoked.

1. Details of the disposition;

A. On October 23, 2009, Nonparty B Co., Ltd. (hereinafter “B”) issued “C Bonds with Warrants” of KRW 4 billion in total face value (hereinafter “instant Bonds with Warrants”) and Nonparty D Co., Ltd (hereinafter “D”) acquired all of them.

B. On November 23, 2009, the Plaintiff, the largest shareholder of B, acquired the warrant certificates of KRW 1 billion in face value (hereinafter “instant warrant certificates”) as KRW 50 million, separated from D’s bonds with warrants of this case.

C. On September 16, 201, the Plaintiff exercised the warrant certificates of this case in KRW 986 per share and was issued B’s 1,014,198 shares.

The director of the Daejeon Regional Tax Office, from May 19, 2014 to July 11, 2014, deemed that the Plaintiff, by exercising the warrant certificates of this case, obtained the stock conversion profit of KRW 976,00,752 [2,00,00 (2,332 won of the stock price - converted price 986 won) ¡¿ (1,014,198 - the number of de facto issued shares - 289,086 shares) in excess of his/her own shares, and notified the Defendant of the relevant taxation data.

E. In applying Article 40(1)2(b) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201; hereinafter “former Inheritance Tax Act”), the Defendant determined and notified the Plaintiff of KRW 347,454,330 (including additional taxes) of gift tax, by applying Article 40(1)2(b) of the same Act.

(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute; Gap evidence 1-2; Gap evidence 2-1, 2-2; Gap evidence 6; Eul evidence 1-5; the purport of the whole pleadings and arguments

2. Whether the instant disposition is lawful

(a) The entry in the relevant statutes are as shown in the attached statutes;

B. Article 40(1)2(b) of the former Inheritance and Gift Tax Act (amended by Act No. 40(1)2 of the former Inheritance and Gift Tax Act) to organize the issues as to whether Article 40(1)2(b) of the former Inheritance and Gift Tax Act applies to the Plaintiff’s acquisition and exercise of warrant certificates of this case among the related parties.