1. On November 6, 2014, the Defendant’s revocation of a disposition rejecting gift tax correction against the Plaintiff.

2. The costs of the lawsuit are assessed against the defendant.

1. Details of the disposition;

A. The non-party C Co., Ltd (hereinafter referred to as the "beneficiary C Co., Ltd.") located in Seocho-gu, Seoul and the non-party C Co., Ltd. located in Seocho-gu, Seoul (hereinafter referred to as the "special relation corporation") are a corporation engaged in drug wholesale business, and the special relation corporation sells all products produced by the beneficiary corporation after receiving delivery.

B. The status of shareholders as of December 31, 2014 based on the register of shareholders of beneficiary corporations and special-related corporations, as the controlling shareholders of beneficiary corporations and special-related corporations, are as follows.

A E A E C

C. On July 31, 2013, the Plaintiff calculated the deemed donation gains pursuant to Article 45-3 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11609, Jan. 1, 2013; hereinafter “former Inheritance Tax Act”) as KRW 362,508,885, and reported and paid KRW 56,251,60,00, gift tax for the year 2012.

On September 17, 2014, the Plaintiff filed a request for correction of the gift tax on September 17, 2014, on the grounds that the beneficiary corporation is not a beneficiary corporation for the day-to-day period under the above provision. On November 6, 2014, the Defendant issued a notice of refusal of the Plaintiff’s request for correction (hereinafter “instant refusal disposition”) on the grounds that the Plaintiff does not fall under the criteria for exclusion of sales with the related corporation under the proviso to Article 34-2(7) of the former Enforcement Decree of the Inheritance and Gift Tax Act (amended by Presidential Decree No. 25195, Feb. 21, 2014; Presidential Decree No. hereinafter “former Enforcement Decree of the Inheritance and Gift Tax Act”).

E. The Plaintiff appealed and filed an appeal with the Tax Tribunal on January 28, 2015, but the Tax Tribunal dismissed the Plaintiff’s appeal on March 26, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 6, 11, and 12 (including each number, if any) and the purport of the whole pleadings

2. The plaintiff's assertion

(a) The co-borns and their spouses, each of whom is registered as 1% shareholders of the beneficiary corporation and the special relationship corporation, are all merely to the title trustee;