The Defendant’s disposition of imposition of gift tax of KRW 115,363,830 against the Plaintiff on May 7, 2013 is revoked.

The costs of lawsuit.

1. Basic facts

A. The Plaintiff is a person who entered a non-listed corporation B (hereinafter “B”) on May 22, 2009 and is engaged in the business of publicizing and selling B products until now.

B. Along with the resolution of the board of directors on April 27, 2010, B issued 15,000 new shares to KRW 10,000 per share (hereinafter referred to as “instant capital increase”) and based on the B’s list of shareholders, the shareholders’ composition and equity ratio before and after the instant capital increase are as listed below.

(C) 12,500 2,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 60 2,500 60 5,000 5,000 2,000 2,000 1,000 1,000 2,000 10 2,000 10 2,000 5,00 00 00 0,000 00 0,000 2,000

C. On May 7, 2013, the Defendant imposed gift tax on the Plaintiff on the ground that the Plaintiff acquired 2,00 shares out of 6,00 shares of forfeited stocks (the shares in this case) that were incurred by the Plaintiff’s waiver of the right to receive new shares through the third party allocation method, and acquired 2,00 shares of the forfeited stocks (the shares in this case) from the Plaintiff as a price lower than the market price. Accordingly, prior to the amendment of Article 39(1)1 (a) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201; hereafter “former Inheritance Tax Act”) by applying Article 39(1)1 (a) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 23591, Feb. 2, 2012); Article 29(3)1 and Article 54 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 487,480,90, Mar. 130, 150, 20000).