1. The Defendant imposed gift tax of KRW 3,753,732,00 on the Plaintiff on July 15, 2013, 2,506,538,400 among the disposition imposing gift tax of KRW 3,753,732,00.

1. Details of the disposition;

A. A Co., Ltd. (hereinafter “Bankruptcy Savings Bank”) is a company declared bankrupt on August 31, 2012 by the Suwon District Court under 2012Hahap23, and the Plaintiff is a bankruptcy trustee of the Savings Bank, who is qualified as a party to the Savings Bank in a lawsuit against the bankrupt estate.

B. On May 15, 2008, the bankrupt bank entered into a credit transaction agreement with the non-party B with the credit limit of KRW 5,000,000 as a comprehensive passbook loan, ② on October 13, 2009, each of the credit transaction agreements with the credit limit of KRW 2,800,000 was executed (hereinafter “each of the loans in this case”), and the B was 2,50,000,000 as a loan under the credit transaction agreement concluded on May 15, 208 (hereinafter “BW”) and changed the B bonds with warrant (hereinafter “C”) of the stock company C (hereinafter “C”) with the same day as the loan amount of KRW 2,80,000,000 to the credit transaction agreement concluded on October 13, 209 (hereinafter “the same date”).

Since then, B repaid the principal and interest of the loan on May 15, 2008, KRW 3.79 billion on June 12, 2009.

C. On July 2012, the Seoul Regional Tax Office conducted a tax investigation on the major shareholders of the bankrupt bank and the bankrupt bank in relation to the insolvency loan case of the bankrupt bank. As a result, the sum of KRW 5 billion loans that the bankrupt savings bank borrowed to B on May 15, 2008 and October 13, 2009 respectively, and the fact is that the bankrupt bank borrowed the name of B, and that the borrower is the bankrupt bank and the trustee is merely the trustee.

Therefore, C and D B acquired by B with the above five billion won loan also belong to the bankrupt savings bank, and the bankrupt savings bank is the title truster and the title trustee.