1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On February 15, 2012, a sales contract was prepared for the Plaintiff’s purchase of KRW 2,000 non-listed shares (hereinafter “instant shares”) issued by C (the father of the Plaintiff and B, who is the father of the Plaintiff and the Plaintiff’s illegal representative) to KRW 30,000,000 per share (hereinafter “instant transaction”). On February 16, 2012, the Plaintiff transferred KRW 30,000,000 from the instant account under the name of the Plaintiff (Korea Bank: E) to the account in the name of B (F).

B. On November 1, 2014, the Defendant assessed the instant shares as KRW 593,032,00 per share ( KRW 296,516 per share x 2,000 per share) based on the supplementary assessment method, and imposed KRW 235,763,140 on the Plaintiff.

(hereinafter referred to as “instant disposition”). C.

The Plaintiff filed an appeal with the Tax Tribunal on August 7, 2015, but was dismissed on October 27, 2015.

[Ground of recognition] Facts without dispute, Gap 1, 2, 8, 10 (including branch numbers, if any; hereinafter the same shall apply), Eul 1 and 3, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s summary of the Plaintiff’s assertion (1) was not a donation of the instant shares from B, but a lawful purchase price was paid and purchased. As such, the transfer of the instant shares constitutes Article 44(3)5 of the former Inheritance Tax and Gift Tax Act (wholly amended by Act No. 11609, Jan. 1, 2013; hereinafter “former Inheritance Tax Act”) and Article 33(3)2 of the Enforcement Decree of the same Act and the provision on presumption of donation is excluded.

Even if the Plaintiff purchased the instant shares at a price lower than the market price, the sales contract of the instant shares is genuine. Therefore, the transfer of the instant shares constitutes a donation of profits arising from a low-price transfer under Article 35 of the former Inheritance and Gift Tax Act, and exceeds the market price.