1. As to the Plaintiff B on June 1, 2017, the decision on collection submitted by the Defendant on June 2, 2017 is made to the Plaintiff A.

1. Details of the disposition;

A. C established a company D (hereinafter “D”) on November 21, 2000, under title trust with E, a person with a special relationship. On July 21, 2001, C transferred 27,000 shares for capital increase and additionally held title trust with 27,000 shares.

B. C re-titled the Plaintiff B with 15,000 shares out of 30,00 shares registered in title to E on October 4, 2002, and 15,000 shares out of 30,00 shares, which were title trusted to E, to the Plaintiff A again, with the offering of new shares on November 16, 199, and with the offering of new shares on December 50, 196, each of 7,500 shares among the Plaintiffs and 130,000 shares out of 19,50 shares to each of the Plaintiffs under title trust with additional 84,00 shares (42,00 shares each of the Plaintiffs).

C. D on July 30, 2008, established F Co., Ltd. F (hereinafter “F”) as a corporation established by division through personal division. Accordingly, the Plaintiffs were allocated a total of 37,800 shares of D, each of which was each nominal trust (18,90 shares, respectively, of the Plaintiffs) in F shares 37,800 shares.

D and F became a complete parent subsidiary through an all-inclusive share swap on November 30, 2013. During this process, C transferred 37,800 shares owned under the name of the Plaintiffs to D and was allocated 35,792 shares of the shares issued by D in the name of the Plaintiffs (hereinafter “instant shares”).

The commissioner of the Gwangju Regional Tax Office shall grant from January 23, 2017 to the same year.

2. 21. After conducting a gift tax investigation with respect to the Plaintiffs, it was confirmed that C’s above stock title trust was made, and it was judged to be a title trust for the purpose of tax avoidance.

3. On October 4, 2002, the Plaintiffs notified the Plaintiffs of the pre-announcement of gift tax taxation based on the constructive gift for each nominal trust as of October 30, 201, November 16, 2002, December 29, 2003, and November 30, 2013.

The plaintiffs filed a request for pre-assessment review with the Director of the Gwangju Regional Tax Office, but the Director of the Gwangju Regional Tax Office decided not to adopt the above request on May 25, 2017.

E. The Director of the Gwangju Regional Tax Office shall make the above findings to the defendant.