Plaintiff

A’s claim against the director of Leecheon Tax Office, and the Plaintiff’s claim against the director of the Nam Tax Office.

1. Details of the disposition;

A. C Co., Ltd. (hereinafter “Nonindicted Company”) is a company established around December 199 and engaged in the business of manufacturing and selling contact lensess.

At present, the representative director and D had been appointed as the representative director of the non-party company from January 6, 2001.

At the time of the establishment of the non-party company, D, the largest shareholder, was each nominal trust with the plaintiff B, who knew of the non-party company's shares of the non-party company, and with the plaintiff A, the spouse of the plaintiff B, the non-party company's shares of 2,00 shares.

B. Plaintiff A transferred 4,400 shares of Non-Party A’s shares to Non-Party D, the representative director and the largest shareholder of Non-Party Company as of September 22, 2015, while he/she received 1,400 shares from capital increase issued on October 1, 2004 as well as 1,40 shares from capital increase issued on February 28, 2008.

C. Plaintiff B owned 4,700 shares of Nonparty Company 4,00 shares (hereinafter “Second shares”), 6,000 shares issued on October 1, 2004, and 14,700 shares issued on February 27, 2008 and held 14,70 shares in shares issued on each of the 6,00 shares issued on the 6,00 shares issued on the 6,00 shares issued on the 6,700 shares, and 3,500 shares that the Plaintiff acquired at the time of the incorporation of Nonparty Company 2, around 2001.

On September 22, 2015, 4,700 shares were transferred to D respectively to E and F, each of whom was 5,000 shares.

As a result of the investigation into the change of stocks with respect to the non-party corporation from October 1, 2017 to October 25, 2017, the head of the North Mine District Tax Office determined that each of the shares (including shares 1 and 2) allocated to the Plaintiffs during the capital increase with respect to the capital of the non-party company for the purpose of tax evasion is deemed to be a gift pursuant to Article 45-2 of the Inheritance Tax and Gift Tax Act (hereinafter “Capital Increase Tax Act”).

E. According to the results of the above tax investigation, the head of Echeon District Tax Office, August 14, 2018, for the Plaintiff A with gift taxing KRW 8,788,630 on shares 1, and the head of E-Nam District Tax Office, for the Plaintiff on February 7, 2019.