1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. From December 12, 2005 to November 31, 2014, the Plaintiff worked as the vice president of a non-listed corporation B (hereinafter “non-listed corporation”) that is a major business objective of manufacturing and selling special paints, etc.

B. On February 14, 2006, the Plaintiff entered into a share transfer agreement with the non-party company’s 6200 shares (hereinafter “instant shares”) that were transferred to Eul, who was the representative director of the non-party company C, to acquire the shares of the non-party company 31 million won (the face value 5,000 won per share). On the same day, the Plaintiff was registered as a shareholder in the register of shareholders.

C. On September 19, 2008, the Plaintiff prepared a gift agreement with E and E, who had the position of the president of the non-party company, by dividing 3,100 shares of this case into 3,100 shares, and E and F reported and paid each of the above 29,50 won of gift tax (69,087 won per share x 3,100 shares) within the gift tax reporting period.

On December 10, 2015, the Defendant evaluated the value of the instant shares as KRW 222,642,00 (value per share, KRW 35,910) and notified the Plaintiff of KRW 76,756,630 (including additional tax) pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (wholly amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”), which is a provision on deemed donation of title trust, pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (wholly amended by Presidential Decree No. 20621, Feb. 22, 2008; hereinafter the same) by applying Article 56(1)1 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (wholly amended by Presidential Decree No. 20621, Feb. 22, 2008).

(hereinafter “instant disposition”) e.

On April 7, 2016, the Plaintiff filed an objection with the Seoul Regional Tax Office, but was dismissed, and filed an appeal with the Tax Tribunal.