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1. On December 1, 2016, the Defendant imposed a gift tax of KRW 64,923,710 (including additional taxes) on Plaintiff A for the year 2014.
Reasons
1. Details of the disposition;
A. C (hereinafter “instant company”) was established on November 15, 2007 with the trade name “D Co., Ltd.” for the purpose of semiconductor and L CD parts processing business, etc., and Plaintiff B acquired new shares of the instant company (10,000, 50%) on April 17, 2008 and was appointed as the representative director, and changed to the trade name as of the same day.
B. Around June 11, 2009, 3,500 shares of E, which were the former shareholders of the instant company, (hereinafter referred to as “1 shares”) were transferred to F (Plaintiff B’s private village residents), to H (hereinafter “2 shares”) the shares of 3,500 shares of former shareholders (hereinafter “2 shares”) were transferred to H (as of June 5, 2009, office directors of the instant company), and 3,000 shares of the former shareholder to the Plaintiff (as of June 5, 2009), respectively.
C. Around November 1, 2010, total 3,500 shares of the first shares held by F and total 6,000 shares out of the shares owned by Plaintiff B (hereinafter “third shares”) were transferred to J (the mother of staff of the instant company), and 2,500 shares out of the shares owned by Plaintiff B (hereinafter “fourth shares”) to H, respectively.
around March 23, 2012, the third shares held by J were transferred to L who was employed as an employee of the instant company from January 1, 2010 (the third shares were transferred to L; hereinafter “5 shares”).
E. Around February 12, 2013, shares 2,500 held by H and shares 2,500 shares 2,500 shares (hereinafter “six shares”) were transferred to M (the two children of Plaintiff B).
F. Around October 17, 2014, KRW 5,00 holding L was transferred to the Plaintiff (as from the time when shares No. 5 were transferred to the Plaintiff, KRW 7) and KRW 6,000 (as from the time when shares No. 6 were transferred to N, KRW 40,000 (as from the time when shares No. 6 were transferred to N, KRW 8,000) and KRW 5,000 (as 40,000 (as 28,000) and 8,000 (as 4,000) were issued at the face value of the instant company, each share offering was made to the Plaintiff.
The year of classification;