1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The relationship between the Plaintiff and B 1) C Co., Ltd. (hereinafter “D”) was changed on October 25, 201 to “D Co., Ltd.”).

hereinafter referred to as “D”

A) A company is established on November 3, 1994 for the purpose of construction business, etc. B) A received D by acquiring D’s shares in D’s major shareholders around 1996, and the Plaintiff was an employee employed to B and worked in D.

B. On October 5, 1996, B loaned the Plaintiff’s name and acquired D’s 12,600 shares from October 5, 1996. Subsequent to the following capital increase with respect to D’s shares held in the Plaintiff’s name from October 201 to October 2010, total amount of 80,220 shares (12,60 shares, 37,800 shares, 10,920 shares, 16,80 shares, hereinafter “instant shares”).

- Acquisition of 37,800 shares with capital increase on September 22, 1997 - Acquisition of 2,100 shares with capital increase on September 29, 199 - Acquisition of 10,920 shares with capital increase with capital increase on August 22, 2002 - Acquisition of 10,920 shares with capital increase with capital increase on August 10, 2004 16,80 shares with capital increase on December 10, 2004) transfer of title to all of the shares of this case under the name of the Plaintiff, but in the process of purchase and capital increase with capital increase, the purchase price of the shares or capital increase with capital increase was fully borne by B, not the Plaintiff.

3) After October 5, 2010, the instant shares were transferred to E, the Dongbook, B, and around October 5, 2010. (c) The Defendant’s assessment of gift tax (including additional tax) on the Plaintiff was confirmed as the result of the investigation of the change of shares on D by the head of the tax office of Ulsan District Tax Office (including additional tax) on the Plaintiff, that the instant shares were trusted in trust to the Plaintiff, and the head of the tax office of Ulsan District Tax Office notified the Defendant of the assessment of gift tax on the Plaintiff, the title trustee.

2) Based on the above investigation, the Defendant: (a) on March 11, 2014, KRW 161,514,740 [including KRW 2,731,890 (including additional tax 630,437) on September 29, 199; (b) on August 22, 2002, KRW 21,954,940 (including additional tax 6,272,841) on December 10, 2004, penalty tax of KRW 136,827,910.