1. The Defendant’s disposition of imposing gift tax amounting to KRW 848,402,70 against the Plaintiff on November 8, 2013 is revoked.

2...

1. Details of the disposition;

A. On December 18, 2009, the Plaintiff: (a) donated 104,415 shares of Nonparty B Co., Ltd. (hereinafter “instant company”; (b) the Plaintiff donated 104,415 shares of the instant company’s representative director C to D, one’s spouse; and (c) on December 24, 2009, D filed a gift tax on the gift amount of KRW 300,819,615 (value per share 2,881 won).

(hereinafter “instant donation”). (b)

Since July 21, 2010, the company of this case listed on the KOSDAQ market and rise the market price of the shares. Since D is deemed to have donated “interest arising from the listing, etc. of shares or equity shares” under Article 41-3 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 2011; hereinafter “Capital Tax Act”), the head of the Dong-gu Tax Office assessed the gift of the shares of this case as KRW 28,05 per share under Article 31-6 (3) and (4) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 23040, Jul. 25, 2011); and assessed the gift of the shares of this case as of the date of settlement - KRW 2,023 per share as of the date of donation - KRW 1,081 per share due to the substantial increase of corporate value, KRW 281,087).

(hereinafter “Prior Disposition”). C.

D, dissatisfied with the instant preceding disposition, filed a lawsuit seeking its revocation with the Suwon District Court on September 26, 201 and upon a request from the Tax Tribunal on January 17, 2012 (hereinafter “instant prior lawsuit”). During the appeal process, D, on November 3, 2011, re-changes the shares donated on September 17, 2037 (the number of shares donated on September 3, 201, increased by free title holders; hereinafter “instant shares”) under the name of the Plaintiff on the ground that the substance of the instant gift was the title trust, and the title trust was terminated.

b.0.0 c.