1. The Defendant’s gift tax of KRW 357,911,110 for the Plaintiff on January 11, 2016, KRW 123,752,710 for the gift tax of KRW 357,91,110 for the year 2012.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “instant company”) was established on March 23, 1995 for the purpose of book manufacturing and publishing business.

The plaintiff's spouse C is the representative director of the company of this case and the plaintiff is the inside director of the company of this case.

B. At the time of incorporation of the instant company, capital is KRW 50 million, and the total amount of shares issued is KRW 10,000.

The current shareholder status of the instant company and the number of shares owned by each shareholder are as follows.

(unit: State) Shareholders C 3,000 3,000 3,000 2,000 4,000 4,000 D 2,000 D 2,000 2,000 2,000 2,000 2,000 E 2,000 2,000 2,000 2,000 E 1,000 1,000 0 Plaintiff F 900 900 9000 G 500 500 0,500 Plaintiff 10 100 Plaintiff 10

C. On September 25, 2012, the Plaintiff purchased 2,000 shares (hereinafter “instant shares”) owned by E, G, and H (hereinafter “E, etc.”) from the shareholders of the instant company, E, G, and H (hereinafter “E, etc.”) in the face value of KRW 5,00 per share.

(hereinafter “share transfer”) D.

The Defendant confirmed the fact that the dividends paid by the instant company to E, etc. on April 1, 2010 through the planning and inspection of low-price trading of stocks of the unlisted corporation deposited into a financial account under the name of E, etc., and the actual owner of the instant shares is C. The actual owner of the instant shares, upon termination of a title trust agreement on the instant shares with E, etc., deemed that C donated the instant shares to the Plaintiff in accordance with the method of appraisal of unlisted stocks under the Inheritance Tax and Gift Tax Act, and assessed the instant shares as KRW 1,580,528,000 (2,00 x 790,264 won per share) in accordance with the method of appraisal of unlisted stocks under the Inheritance Tax and Gift Tax Act, and notified the Plaintiff of January 11, 2016, on January 11, 2016.

(hereinafter referred to as "the disposition of this case". (e)

Accordingly, the Plaintiff filed an objection on February 25, 2016, but was dismissed. On July 1, 2016, the Plaintiff filed an appeal with the Tax Tribunal, but was dismissed on September 23, 2016.

[Ground of recognition] Unsatisfy, Gap evidence 1, 2, Eul evidence 1, 3, and 5 (which include each number).