1. On February 1, 2014, Defendant Samsung Tax Office’s penalty tax amounting to KRW 1,236,458,773, which was paid to Plaintiff A for the year 2012.

1. Details of the disposition;

A. The plaintiff A is the wife of D, who is the representative director of C Co., Ltd. (hereinafter "C"), and the plaintiff B is the infant between D and the plaintiff.

In addition, E is the dynamics of Plaintiff A, and F are the relatives of Plaintiff A.

B. According to Article 45(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11609, Jan. 1, 2013; hereinafter “former Inheritance Tax Act”), the director of the Gwangju Regional Tax Office, upon conducting a tax investigation in around 2012, deemed that D was a gift of KRW 1,495,975,410 to the Plaintiff and KRW 284,313,533 to the Plaintiff (hereinafter “first gift”) pursuant to Article 45(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11609, Jan. 1, 2013; hereinafter “former Inheritance Tax Act”), imposed a gift tax of KRW 208,792,62,623 to the Plaintiff and KRW 40,862,706 on the grounds that the Plaintiffs failed to fully explain the source of the

(hereinafter the sum of each amount of gift tax paid as above is referred to as the “paid tax amount of this case”).

On the other hand, on August 31, 2012, the statement of the change of stocks, etc. in C, on the following grounds: (a) Plaintiff A’s 54,00 shares of the said company from E (hereinafter “E-registered shares”); (b) Plaintiff B’s 5,00 shares of the said company from F; and (c) combined with the shares in the said E-registered shares.

E was described as having received each of the above shares, and E was entrusted with the title of 54,000 shares of the above company as listed below. In December 27, 1999, the acquisition time was 8,800 shares of shares issued with capital increase with capital increase with capital increase, which was 2,800 shares issued with capital increase, which was 2,800 shares issued with capital increase, which was 2,800 shares issued with capital increase, which was 2,800 shares issued with capital increase, which was 2,800 shares acquired with capital increase, which was 2,800 shares issued with capital increase, which was 2,800 shares issued with capital increase, in 199

D. As a result of the examination of changes in stocks conducted by C from October 17, 2013 to December 20, 2013, the Director of the Gwangju Regional Tax Office: (a) determined that the actual owner of the instant stocks was D; (b) that D was a title trust of the said stocks to E and F; and (c) that the said stocks were donated bypass to the Plaintiffs in the form of transfer.