1. Imposition of gift tax of KRW 333,045,512 against the Plaintiff on August 1, 2017, and imposition of gift tax of KRW 333,045,512 on the Plaintiff on February 8, 2018.

1. Details of the disposition;

A. From April 4, 2011 to October 30, 2014, the Plaintiff completed the registration of ownership transfer in the name of the Plaintiff as to each real estate listed in paragraphs (1) through (5) of the attached Table (hereinafter collectively referred to as “each of the instant real estate”) as indicated in the following table. When individually named, the Plaintiff completed the registration of ownership transfer in the name of the Plaintiff regarding each of the instant real estate ①, “the instant real estate”, “the instant real estate”, and “the instant real estate ③” in order.

On April 4, 2011, the amount of secured loan, including the acquisition value of real estate as of the date of acquisition, on April 31, 201:

B. The Defendant presumed that, from the total purchase price of each of the instant real estate to be KRW 3.35 billion (i.e., acquisition price of KRW 3.185 million (i., acquisition price of KRW 1.29,35 million), KRW 1.83 billion less the total amount of KRW 94 billion including KRW 1.399 billion and deposit money, etc., the Defendant donated KRW 1.83 billion to the Plaintiff, who is the Plaintiff’s spouse, on August 1, 2017, imposed a disposition imposing gift tax of KRW 535,143,636 on the Plaintiff (hereinafter “instant disposition”).

C. The Plaintiff dissatisfied with the instant disposition ① and filed a request for examination with the Commissioner of the National Tax Service on September 7, 2017, but the Commissioner of the National Tax Service dismissed the Plaintiff’s request for examination on November 17, 2017.

On February 8, 2018, the Defendant: (a) revoked ex officio the portion of KRW 202,098,124, which was disposed of on January 31, 2013 as of the date of donation among the instant dispositions; and (b) subsequently imposes KRW 209,490,208, which was determined on October 31, 2012 as the date of donation, on October 31, 2012, which was determined as the date of donation (hereinafter “instant disposition”); (c) the Defendant is deemed to be “instant disposition”; and (d) KRW 33,045,512, which was not revoked ex officio among the instant dispositions (i) KRW 535,143,636, which was determined as the date of donation; and (e) the Defendant is subject to a disposition imposing KRW 209,49,20