1. Revocation of a judgment of the first instance;

2. The Defendant imposed a gift tax of KRW 2,875,445,790 on the Plaintiff A on June 3, 2013.

1. The grounds for the court’s explanation on the background of the disposition, the parties’ assertion, and this part of the facts alleged by the parties are as stated in the judgment of the court of first instance, except for the following additional or further portions, and thus, this part of the reasoning is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

The following shall be added to the 7th sentence below the 3th sentence of the first instance judgment:

In this regard, “A and B” did not submit any documentary evidence of the same assertion as the time of the initial investigation, but did not have any reason to believe that the content of the initial investigation is unjustifiable, and the report of completion of stock change (Evidence B) with the content that “A and B shall decide as the same as the initial investigation, and shall be completed as the result of the initial investigation,” and the report of completion (Evidence B) of the stock change (Evidence B) with the content that “B Nos. 1 and 2 (including each number)” was written on the 3rd page of the judgment of the first instance.

The following shall be added to the fourth sentence below of the first instance judgment:

In addition, even though the Tax Tribunal rendered a re-audit decision on September 2, 2014 to the effect that it will re-examine who is the owner of the shares in this case and determine the tax base and tax amount according to the result, the defendant issued the disposition in this case to the same effect as that of the previous case without a substantive re-audit, and thus

Under the fourth sentence of the judgment of the first instance, the first instance court held that the phrase “it is difficult to recognize its authenticity as it is,” and that it cannot be presumed that it has been duly formed since it was in fact without going through the procedures under the Notary Public Act.”

On the 11th day below the text of the first instance judgment, “The appeal is currently pending (Seoul Eastern District Court 2017Na20908)” was sentenced, and all appeals were dismissed and finalized.

(Seoul Eastern District Court 2017Na20908, Supreme Court 2017Da294691).