1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From August 1, 2011 to November 10, 201, the Director of the Central Regional Tax Office: (a) confirmed that the deceased opened a securities account (Account: Account Number: C, D, and hereinafter “instant account”) in the Plaintiff’s name from 2002 to 2009 and confirmed that the deceased purchased and sold shares, etc.; and (b) applied the provision on the constructive gift of title trust property to the date of preparation of the register of shareholders, and notified the Defendant of the taxation data on the shares (hereinafter “instant shares”) deposited in the instant account from 2002 to the last day of the year 2009, the date of preparation of the register of shareholders, by deeming that the deceased held the title trust shares with the Plaintiff as the nominal shares (hereinafter “instant shares”).

B. Accordingly, the Defendant imposed upon the Plaintiff the gift tax on March 5, 2012; KRW 5,060,100 on the gift tax on the gift of December 31, 2003; KRW 110,927,020 on the gift of December 31, 2004; KRW 89,971,300 on the gift tax on the gift of December 31, 2005; KRW 4,307,360 on the gift of December 31, 206; KRW 4,084,760 on the gift of December 31, 207; and KRW 78,283,08,0 on the gift of December 31, 2009.

(hereinafter referred to as "each of the dispositions of this case")

On June 1, 2012, the Plaintiff appealed to the Tax Tribunal, but was dismissed on December 31, 2012.

[Ground of recognition] Facts without dispute, Gap's 1, 2, 3, 6 evidence, Eul's 1 to 11, the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The Plaintiff’s assertion 1) The Deceased’s assertion of non-existence of the purpose of tax avoidance was seriously in the business due to the IMF foreign exchange crisis, and thus, he was in arrears with taxes equivalent to KRW 2 billion due to the joint and several liability of his representative company or the secondary tax liability, and was the bad credit holder due to the delay in repayment of the loan to the financial institution. The Deceased was the largest shareholder to escape from the financial crisis (hereinafter “E”).

There was trying to make an investment in shares by receiving provisional payments from them.