1. On June 23, 2015, the Defendant imposed acquisition tax of KRW 104,324,550 on the Plaintiff and special rural development tax of KRW 8,922,370 on the Plaintiff.

1. Details of the disposition;

A. From May 18, 2007, the Plaintiff is a person in charge of the representative director of B Co., Ltd. (hereinafter “instant corporation”) established for the purpose of manufacturing and selling machinery, metal type, etc. from May 18, 2007 to the date.

B. The details of stockholding of the instant corporation in the specifications on the changes in stocks are as follows.

On May 18, 2007 (Incorporation) October 6, 2011, 200 C- - 27,600,806.02 - 82,80,000,000 - 180,000,000 - 00,000 - 180,000,000 - 00,000 - 00,000 - 18,000 - 0,000 - 00,000 - 3,00,00,000 - 3,00,00,00 - 3,00,00,000 - 3,00,005,00,000 -6,000,000 - - 6,06,005 - - 6,06,006

C. The Defendant acquired 91,800 shares of the instant corporation from C and D on December 31, 2012 when the Plaintiff owned 8,200 shares of 18,00 shares issued by the instant corporation, and owned 180,00 shares of the instant corporation (hereinafter “instant shares”) and did not file a return or pay acquisition tax, etc. even though the first oligopolistic shareholder became liable for tax payment, on the ground that the Plaintiff did not pay acquisition tax, etc. even though the first oligopolistic shareholder became liable for tax payment, on June 23, 2015 (hereinafter “instant disposition”).

On August 6, 2015, the Plaintiff requested the Tax Tribunal for a trial on August 6, 2015, but the Tax Tribunal dismissed the request on November 10, 2015.

[Ground of recognition] Facts without dispute, entry of Gap evidence 1 to 4, purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is an actual owner who owns 100% of the shares of the instant legal entity from the time of the establishment of the instant legal entity. However, in order to satisfy the requirements for establishment that at the time of incorporation, at least three promoters (shareholders) are required, part of the shares of C, D, and E were nominal trust.

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