1. The Defendant’s disposition imposing gift tax amounting to KRW 765,751,520, which was imposed on the Plaintiff on February 1, 2015, shall be revoked.

2. The costs of lawsuit shall be.

1. Details of the disposition;

A. As the representative director of B Co., Ltd. (hereinafter “instant company”), the Plaintiff acquired 362,174 shares of the instant company (hereinafter “instant shares”) from C without any special relationship on October 15, 2012 at KRW 1,210,747,682 per share (hereinafter “instant shares”).

(hereinafter “instant transaction”). B.

Article 60 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 1357, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”); Article 20 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 24441, Mar. 23, 2013; hereinafter “Enforcement Decree of the former Inheritance Tax and Gift Tax Act”).

() Pursuant to Article 49(1) and (2), the market price of the instant shares at the time of the instant transaction was assessed as KRW 9,000 per share, and the Plaintiff’s acquisition of the instant shares from C without any special relationship to KRW 3,343 per share, which is a significantly lower price than the said market price, constitutes a donation of profits arising from the acquisition of property at a low price under Article 35 of the former Inheritance Tax and Gift Tax Act, and thus, the gift interest was assessed as KRW 1,748,818,318, and the gift tax was assessed as KRW 765,751,520 (including additional tax) on February 1, 2015.

hereinafter referred to as "disposition of this case"

(c) On April 28, 2015, the Plaintiff dissatisfied with the instant disposition and filed a request for an inquiry with the Tax Tribunal on April 28, 2015, but on November 11, 2015, the Plaintiff rendered a decision to dismiss the Plaintiff’s claim by the Tax Tribunal. The Plaintiff did not have any dispute over the grounds for recognition, and the purport of the entire pleadings, as indicated in subparagraphs 1, 2, 4, 1, 2, 1, 2, 3-1, 3-2, and 3-2.

2. Summary of the parties' arguments;

A. At the time of the Plaintiff’s assertion, the Plaintiff and C determined the value of the instant shares as KRW 3,343 per share in accordance with the supplementary assessment methods stipulated in the Enforcement Decree of the former Inheritance and Gift Tax Act, and the merger to be effected in the future cannot be known to what effect the instant company could have been affected, and thus, considered the merger plan.