1. The Defendant’s imposition of KRW 1,539,98,560 against the Plaintiff on September 3, 2012 shall be revoked.

1. Details of the disposition;

A. On December 31, 2004, the Plaintiff: (a) donated 20,000 shares issued by C (hereinafter “C”) from his father on December 31, 2004; (b) owned the entire shares issued by C; and (c) assessed the above shares as KRW 1,514 per share and reported and paid KRW 8,100,000 per share.

B. Since February 6, 2006, the Plaintiff obtained a loan of KRW 400 million from the Korea Securities Finance Bank Co., Ltd. (hereinafter “D”) to cover KRW 80,000 (amount assessed to KRW 640,80,000) of D Co., Ltd. (hereinafter “D”), and on February 8, 2006, the Plaintiff participated solely in C’s capital increase with capital increase and additionally acquired KRW 80,00,000 from C’s capital increase.

(hereinafter referred to as “instant shares”) 100,000 shares of C. C

On July 15, 2009, the Plaintiff entered into a contract with Samsung Shipping Co., Ltd. (hereinafter referred to as "buschi Shipping") to transfer the instant shares in KRW 3.5 billion, and on August 13, 2009, transferred the instant shares to Samsung Shipping.

The Plaintiff reported and paid KRW 274,473,360 on November 30, 2009 on the ground that he/she obtained transfer income of KRW 3,052,204,00 from the transfer of the instant shares.

The director of the Seoul Regional Tax Office conducted an investigation of stock change with C during the period from April 30, 2012 to June 29, 2012, and thus, since the value of the instant shares has increased by "other person's contribution", he/she shall be investigated as subject to gift tax pursuant to Article 2 (3) of the former Inheritance Tax and Gift Tax Act (Amended by Act No. 9269, Jan. 1, 2010; hereinafter "Act"), and shall be subject to gift tax pursuant to Article 42 (4) of the Act and Article 31-9 (6) and (7) of the Enforcement Decree of the same Act (Amended by Presidential Decree No. 22042, Feb. 18, 2010); accordingly, the head of the Seoul Regional Tax Office notified the Defendant of the tax status determination on August 31, 2012, regarding KRW 2,92,564,169 as the value of the instant shares transferred to the Plaintiff as the value of property to the Defendant.