1. The Defendant’s imposition of gift tax of KRW 316,623,155 (including additional tax) against the Plaintiff on June 22, 2018 shall be revoked.

1. Details of the disposition;

A. On October 10, 2007, the Plaintiff filed a tax base return on gift tax with the value of KRW 2,750 per share of January 10, 2008, and the value of donated property KRW 13,750,000, under the premise that he/she received the donation of KRW 5,000 (hereinafter “instant shares”).

B. On February 8, 2013, the Plaintiff filed a revised return with the value per share of the instant shares as KRW 173,913, and the value of donated shares as KRW 869,565,217, and paid KRW 316,623,155 (including additional taxes) for the gift tax.

C. On July 4, 2013, when the Plaintiff was not notified of the assessment standard of gift tax and the amount of tax, the Plaintiff demanded the Defendant to correct the reduction on the ground that the value per share of the instant shares is KRW 2,750, but the Defendant did not give any notice within two months thereafter.

On the other hand, on October 10, 2007, the Plaintiff-friendly D also filed a tax base return on gift tax with the value of 2,750 won per share on January 9, 2008, under the premise that C was donated 4,000 shares issued by C from October 10, 207.

On February 12, 2014, the head of the same district tax office rendered a decision of KRW 311,022,520 regarding the value per share of the above shares as KRW 173,913 won, and D received a favorable decision on July 24, 2015 on the ground that it is difficult to regard the value per share of the above shares as KRW 173,913 won by filing an appeal litigation seeking the revocation of the above disposition (Seoul District Court 2015Guhap20375), and the appeal by the head of the same district tax office against this decision was dismissed on June 10, 2016 (Seoul High Court 2015Nu22479), and the above decision became final and conclusive around that time.

E. On August 4, 2016, after the Plaintiff completed the move-in report with E Apartment and F, the Plaintiff filed an application for rectification based on the aforementioned judgment with the director of the Namyang District Tax Office. However, on September 30, 2016, the director of the Namyang District Tax Office was not a party to whom the said judgment was rendered, and thus, on the ground that the said application does not fall under the grounds for post-ex post-explosion rectification under Article 45-2(2)1 of the Framework Act