1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. B Co., Ltd. (formerly named “C Co., Ltd.” or “D Co., Ltd.”; hereinafter “instant company”) is a company operating Smarket.

B. On January 8, 2005, the Plaintiff acquired 10,400 shares of the instant company (hereinafter “instant shares”) that were transferred from E under the name of E, and completed the transfer procedure around that time.

C. The Defendant: (a) deemed that the Plaintiff was deemed to have received title trust from F; and (b) applied the provision on deemed donation of title trust under Article 45-2(1)1 and (3) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8139, Dec. 30, 2006; hereinafter the same) to the effect that the Plaintiff donated the instant shares from F; (c) assessed the instant shares as KRW 21,205 per share; and (d) decided and notified the Plaintiff on December 1, 2014 as gift tax of KRW 172,870,620 per share.

Since then, the Defendant’s amount of tax to be deducted from the above amount of tax on March 12, 2015, the sum of KRW 78,037,44,440, and KRW 94,80,00,00,000,000,000 for total of KRW 17,564,590 on June 2, 2015, and the amount of gift tax to be imposed on the Plaintiff for 2005, left to 94,83,180, including penalty tax.

(A) As seen above, the Defendant’s disposition of gift tax on December 1, 2014, which was imposed on the Plaintiff on December 1, 2014, regarding the remaining amount of tax that was reduced as above (hereinafter “instant disposition”).

On December 3, 2015, the Tax Tribunal dismissed the Plaintiff’s request for a trial on the grounds that the Plaintiff was dissatisfied with the instant disposition and filed a request for a trial with the Tax Tribunal.

E. During the instant lawsuit pending, the Defendant added the grounds for the instant disposition to the effect that “the Plaintiff received the title trust of the shares of this case from the Korea Egyptive Meeting.”

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1, 2, and 13 (including branch numbers), and arguments.