1. A donation contract concluded on July 7, 2016 between Defendant A and F on each of the real estates listed in the separate sheet.

1. Basic facts

A. On March 14, 2016, F transferred F-owned land H, I, and J to G, Gyeong-gun, Gyeong-gun, G, and calculated capital gains tax amounting to KRW 83,448,045 on April 15, 2016 and filed a return on estimated income for tax base of transfer income, but did not pay capital gains tax.

On July 11, 2016, the head of the competent tax office notified F to pay capital gains tax of KRW 84,474,455, including penalty tax.

Since then, F did not pay the above capital gains tax, and as of December 2018, F reached KRW 115,392,000 in the aggregate of the capital gains tax and additional dues.

B. On July 7, 2016, F entered into a gift agreement (hereinafter “instant gift agreement”) with Defendant A, the wife, and each real estate listed in the separate sheet (hereinafter “each of the instant real estate”), with respect to each of the instant real estate listed in the separate sheet (hereinafter “each of the instant real estate”). On July 8, 2016, F entered into an agreement on the gift (hereinafter “instant gift agreement”) with Defendant A with respect to each of the instant real estate, and completed the registration of transfer of ownership based on the instant gift agreement pursuant to Article 12139 with respect to each of the instant real estate (hereinafter “instant real estate”).

C. Each of the instant real estate was owned by the original F’s license, and the network K died on February 27, 2015, and the F transferred the ownership of each of the instant real estate on February 27, 2015 due to an inheritance by consultation or division.

On February 26, 2004, the Network K entered into a purchase and sale promise with respect to the real estate of this case (hereinafter “the instant purchase promise”) with Defendant B, C, D, and E on February 26, 2004, and the said Defendants entered into a provisional registration claim for ownership transfer registration based on the instant purchase promise (hereinafter “the instant provisional registration”) with the Changwon District Court’s High Registry receipt No. 3023. 3023.

At the time of entering into the gift contract of this case, F’s active property is the real estate No. 1 (50,559,000 won) of this case, the real estate No. 2 and 3 of this case (a total of 54,000,000 won) and the land price No. 1 of this case and the land price No. 54,00 in Gyeongnam