1.PA 2. RedB

A. Plaintiff LA:

(1) The portion exceeding the OOO personnel in the disposition of imposition listed in the attached Table 1 No. 1 attached hereto issued by the head of Gangnam Tax Office;

(2) The director of the tax office of Leecheon-cheon;

(A) the portion exceeding the OOO members of the disposition of imposition listed in No. 2 List 1;

(B) the portion exceeding the OOO members of the disposition of imposition listed in No. 2 List No. 2;

(C) the portion exceeding the OOO members of the disposition of imposition listed in No. 2 List 3;

(D) Of the disposition imposing No. 4 in the separate list No. 2, the part exceeding the OO members.

Each revocation,

B. The disposition of imposition listed in [Attachment No. 6] No. 6 and the disposition of imposition listed in [Attachment No. 2] No. 6 against the Plaintiff HongB by the Defendant KB shall be revoked.

C. The plaintiffs' remaining claims against the defendants are dismissed.

2. Of the total costs of the litigation:

A. The Plaintiff’s largestA,

(1) 80% of the portion arising between Defendant Kang Dong Tax Office is the above Plaintiff, and the remainder is the above Defendant:

(2) 85% of the portion arising between Defendant Leecheon Tax Office is the above Plaintiff, and the remainder is the above Defendant.

Each share,

B. 75% of the portion arising between the Plaintiff HongB and the Defendant Kamb Tax Office shall be borne by the said Plaintiff, and the remainder by the said Defendant, respectively.

Each of the dispositions in the separate sheet Nos. 1 and 2, which the Defendants filed against the Plaintiffs, shall be revoked (the Plaintiffs changed part of the lawsuit as above in accordance with the Defendants’ partial revocation of the previous dispositions and the second imposition disposition, and the changes in the disposition disposition were corrected as shown in the separate list Nos. 1 through 4).

2. Purport of appeal

(1) In light of the purport of the entire arguments of this case, including the amendment of the purport of the plaintiff's claim, the revocation of the defendant's previous disposition ex officio and the second imposition disposition, the purport of appeal by the plaintiffs

A. The plaintiffs

It shall be amended as stated in the purport of the claim by the judgment of the first instance, including a claim for exchange change in the trial.

B. The Defendants

The judgment of the first instance, including a claim for exchange change in the trial, shall be amended as follows:

The plaintiffs' claims against the defendants are dismissed in entirety.

(1) The CCC Co., Ltd. (hereinafter referred to as "CC") was established on June 1, 1970 for the purpose of manufacturing fruits and feed, and Category DD is the representative director of the CCC; (2) The Seoul Regional Tax Office, after investigating the details of changes in shares of the CCC, entered Category DD in [Attachment 1] to the head of the CCC and the KCC head of the CCC; (3) from October 24, 200 to November 15, 2005, purchased CCC shares 97,285 shares or received capital increase; and (2) from October 17, 2000 to November 21, 2000, entered the list of the Plaintiffs in [Attachment 1] and each of the instant tax office’s respective disposition of imposition of additional tax on shares (hereinafter referred to as “Defendant 1”) and notified each of the instant disposition to the head of the CCC’s 368,741, respectively.

2. Whether each of the dispositions of this case is legitimate

A. Summary of the plaintiffs' assertion

(1) The assertion that title trust was not established

The Plaintiffs only opened a securities transaction account in their names at the request of DoD, and there is no specific agreement on whether or not they are DoD and stock transactions, their size, the type and volume of shares, and there is no specific agreement on each of the instant shares. Thus, no title trust is established with respect to each of the instant shares.

(2) The non-existence of the purpose of tax avoidance

Even if family title trust is recognized, its main purpose was only the price manipulation of CCC shares, not the tax avoidance, but it was not the tax avoidance. However, the reduction of minor tax burden has occurred in the process, so the purpose of tax avoidance is not recognized.

(3) Claim for the return of donated property

“Inasmuch as the shares in the Plaintiff RedB were sold within three months after the title trust was held, it shall be deemed that no gift was made from the beginning in accordance with Article 31(4) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 6780, Dec. 18, 2002; hereinafter “Inheritance Tax and Gift Tax Act”).

Since the new shares acquired with the funds for selling the shares trusted in the name of the plaintiffs shall be deemed as a substitute for the shares initially held in title trust, it is unlawful to consider that the secondary shares were re-title trust and impose tax on them as a donation.

(5) Illegal assertion in calculating the gift value

Even if deemed donation under a title trust under the Inheritance Tax and Gift Tax Act, it is unlawful to calculate the gift value based on the market price formed artificially by DoD, etc. using the share price manipulation. In addition, the base period for calculating the tax base for shares issued with capital increase on October 24, 2000, the transfer date, is December 31, 2000, which is the transfer date, and the gift value per share should be calculated based on the OOO value per share as of December 8, 200. The Defendants calculated the gift value based on the OOO value per share as of December 8, 200, the payment date of shares.

(6) Claim that the requirements for deemed donation due to the sale of shares before the transfer of ownership do not meet

Since Category DD purchased shares in the name of Plaintiff HongB on October 24, 2000, 85,094 shares were sold on or before December 31, 200, the date of entry of change of holders, the transfer of holders did not meet the requirements for deemed donation because the transfer of holders did not comply with the requirements for deemed donation.

B. Relevant statutes

The entries in the attached statutes are as follows.

C. Facts of recognition

(1) The primary market price manipulation;

CategoryD controlled the market price of the shares using ParkF, KimGG, through several borrowed accounts from April 6, 200 to September 5, 2000 for the purpose of selling approximately 230,000 shares of EE, which are a major shareholder of CCC, and sold the shares to approximately KRW OO and deposited the price into the securities account of EE (2) second price manipulation.

① At around October 200, Doz requested the Plaintiffs, Park H-H, II, ChoJ, HaK, etc. to open and change a borrowed account. On September 2000, 200, Plaintiff LA, as a means of tax calculation, opened and opened an investment securities account (O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O-O) of Korea Investment Securities account on November 27, 2000. < Amended by Presidential Decree No. 17097, Nov. 27, 2000>

② Around September 2000, AE withdrawn approximately KRW OOOO from the securities account, and deposited them into its personal account or CCC account through a complex fund laundering process, and deposited them into the securities account under the names of the Plaintiffs, Park HH, Ha II, and HaK, and operated the market price by purchasing and selling shares in its name.

(3) Details of stock trade (including stock allocation through oil increase) made by CategoryD using the Plaintiffs’ account and the details of imposition of the initial gift tax by the head of the Gangwon-do Tax Office and the Director of the Gangwon-do Tax Office are as follows:

See Table 7 pages of the Court Decision

(3) Criminal punishment for stock price manipulation

Category DD ordered CCC stocks to sell and purchase them through several borrowed accounts, including SouthL, in order to artificially control the market price of stocks (the first price manipulation), including the plaintiffs, by artificially placing an order to attract the transaction of CCC stocks from May 2, 2000 to August 25, 2000 (the first price manipulation), and issued a false order to purchase and sell stocks of CCC from October 12, 200 to November 21, 200, with the aim of inducing the transaction of stocks through 20 borrowed accounts, such as Park HH, HK, and HaK, and le II, including the plaintiffs, and issued a final judgment on October 23, 200, the above judgment became final and conclusive on October 23, 200 and became final and conclusive on October 21, 201.

(4) Criminal punishment for violation of change reporting obligation and change of stocks

① From February 7, 2005 to February 11, 2005 to 31, 2004, Category DD violated 12 shares of the CCC (50.54%) 10,512,254 shares, including shares in an account in the name of KimM (50.54%) by failing to report to the Financial Supervisory Commission and the Exchange. From November 12, 2004 to November 12, 2004, 8,552,271 shares of CCC (41.12%) were owned by 12 borrowed accounts, such as accounts in the name of the principal and KimM (41.12%) but it became final and conclusive that the CCC shares were 8,52,271 shares (41.12 shares ratio) by failing to report to the Securities Futures Commission and the change of shares that occurred from February 7, 2005 to February 11, 2005.

② Meanwhile, among the 12 borrowed accounts listed in the above facts constituting the crime, securities trading accounts in the name of the Plaintiffs, which were used for the second manipulation of market prices, are included therein.

(5) Change of title

CCC issued new shares with capital increase and then closed the register of shareholders as of October 24, 2000, and thereafter changed the entry of the shareholders as of the end of each year. The shares of the plaintiffs were changed accordingly.

[Reasons for Recognition] Unsatisfy, Gap evidence Nos. 3 through 8, Eul evidence Nos. 7 through 11, the purport of the whole pleadings

D. Determination

(1) As to the assertion that title trust was not established

(A) The actual owner of each of the instant shares

The above evidence and facts are as follows: ① DoD 2 was in violation of the Securities and Exchange Act by 20 out of 20 accounts, including HH, K, and II. From October 12, 200 to November 21, 200; ② DoD 2 was prosecuted for the crime of 200, and was convicted of violation of the above Securities and Exchange Act; ② DoD 2 was in violation of the 20th order issued from April 6, 200 to September 5, 200, 2300 shares were in violation of the 20th order issued by the 20th order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 1st order issued by the 2nd order issued by the 2nd order issued by the 2nd order issued by the 3rd order.

Article 41-2(1) of the Inheritance Tax and Gift Tax Act provides that, where the actual owner and the nominal owner are different from each other in cases of property (excluding land and buildings; hereafter the same shall apply in this Article), the value of such property shall be deemed to have been donated to the actual owner on the day on which the actual owner registers, etc. as the nominal owner, notwithstanding Article 14 of the Framework Act on National Taxes. As such, in cases of property requiring a registration, etc. for the transfer or exercise of rights, where the actual owner and the nominal owner have made a registration, etc. in the future under an agreement or communication between the nominal owner and the nominal owner, the said provision shall not apply in cases where the registration is unilaterally made in the nominal owner regardless of the intent of the nominal owner. In such cases, if the tax authority proves that the actual owner is different from the nominal owner, it shall be proved that the unilateral act of the actual owner was done by the nominal owner regardless of the intent of the nominal owner (see, e.g., Supreme Court Decision 2

As seen earlier, the actual owners of each of the instant shares are DoD, and the Plaintiffs voluntarily opened a securities transaction account under their names at the request of DoDD, and each of the instant shares was transferred to the Plaintiffs’ name. Therefore, the Plaintiffs are deemed to have donated each of the instant shares from DoD pursuant to Article 41-2(1) of the Inheritance Tax and Gift Tax Act.

As to this, the plaintiffs asserted that title trust is not established since there was no specific agreement between the plaintiffs and DoD on the size, type, and quantity of the shares traded using the securities transaction account under the plaintiffs' names. However, it is reasonable to view that the bank opened the securities transaction account under one's own name at the request of the other party and that the other party will engage in the stock transaction under one's own name in light of the social common sense. As such, the plaintiffs must prove that the transfer of the shares in this case was made under one's own name regardless of the plaintiffs' intent, and that the transfer of the shares in this case was made under one's own act regardless of the plaintiffs' intent, and there is insufficient evidence to acknowledge such fact.

Therefore, the plaintiffs' above assertion is without merit.

(2) As to the non-existence of the purpose of tax avoidance

The legislative purport of Article 41-2(1) of the Inheritance Tax and Gift Tax Act is to recognize an exception to the substance over form principle in the purport that the act of tax avoidance using the title trust system is effectively prevented, thereby realizing the tax justice. Thus, if the title trust was recognized to have been made for reasons other than the purpose of tax avoidance, and it is merely a minor reduction of taxes incidental to the said title trust, it cannot be readily concluded that there was an objective of tax avoidance in the title trust. However, in light of the legislative purport as seen above, only if the purpose of the title trust is not included in the purpose of tax avoidance, it cannot be deemed that there was a deemed donation by applying the proviso to the said provision, so it cannot be deemed that there was an intention of tax avoidance, and the burden of proving that there was no purpose of tax avoidance in this case exists a person who asserts it (see Supreme Court Decision 2007Du1931, Apr.

Based on the above evidence and facts, the following circumstances are acknowledged as follows: ① DoD has made a price manipulation of stocks by means of trading the stocks of the CCC using the Plaintiffs’ account; however, DoD has reduced global income tax and transfer income tax by trading the stocks under the Plaintiff’s name; and the reduced global income tax and transfer income tax by trading the stocks under the Plaintiff RedB’s name are about OOB, and the reduced global income tax and transfer income tax are up to approximately KRW 0OB, and it cannot be deemed that there was a minor tax reduction incidental to the title trust. ② The existence of the purpose of tax avoidance due to the title trust should be determined at the time of the title trust. As NN has been holding more than 3% of the stocks of the CCC, it is reasonable to deem that the transfer income tax was subject to the payment of transfer income tax if it was transferred by the CCC’s share price increase due to the price manipulation, etc., and thus, it is reasonable to have distributed the stocks under the names of the Plaintiffs, etc., and thus, even if each of the CCC’s stocks increase in the purpose of title trust price increase.

Therefore, the plaintiffs' above assertion is without merit.

(3) As to the assertion that donated property is returned

Article 31(4) of the Inheritance Tax and Gift Tax Act that provides that where the donated property (excluding money) is returned within the time limit for report under Article 68 by an agreement between the parties concerned after the donation, it shall also apply to the constructive gift resulting from the title trust of shares. This is because even if the requirements for the taxation of gift tax have already been met due to the title trust of shares, a transfer of the title to the actual owner in the future within a given conversion period can make the actual owner of trust stocks manifest the tax avoidance and make the real name of shares available to prevent tax avoidance and promote the real name of shares by giving the actual owner of trust stocks. However, if a trust owner, who is the real owner, sells shares in the stock market without changing the name in the future, is deemed to be included in the case of immediate sale in the stock market without changing the name in the name of the actual owner, it would result in giving the above benefits under the condition that the first real owner, who is the

In addition, since the property deemed to have been donated by the trustee when the title trust of shares is held, because it is not the purchase price of the shares, it cannot be deemed that the property donated by the trustee was returned itself, and it is difficult to view the sale price as return in the securities account of the trustee," and therefore, it cannot be deemed that the return of the property donated under Article 31(4) of the Inheritance Tax and Gift Tax Act is not the "return of the property donated by the plaintiff HongB". Thus, the above assertion by the plaintiff HongB is without merit (However, as to whether the plaintiff HongB sold the shares of this case before the transfer of title trust, thereby failing to meet the requirements of Article 41-2(1) of the Inheritance Tax and Gift Tax Act by selling the shares of this case before the transfer of title trust, it is examined in the following (6)).

① The requirements for deemed donation under Article 41-2(1) of the Inheritance Tax and Gift Tax Act are “where the actual owner and the nominal owner are different from the property that requires the transfer of the right or the exercise of the right thereto.” However, as seen earlier, the legislative purport of Article 41-2(1) of the Inheritance Tax and Gift Tax Act is to recognize exceptions to the principle of substantial taxation with the purport that effectively prevent tax avoidance by using the title trust system, thereby realizing the tax justice. Therefore, if each of the two different periods differently satisfies the requirements for deemed donation, gift tax should be imposed, based on the substance, such as the identity of the fund, which is the background of each title trust, and it seems not to re-examine whether the above requirements are satisfied. ③ Even if the newly purchased shares are all of the shares of the CCC, which are newly purchased shares, the above shares cannot be deemed the same shares, and ④ since the property deemed as donated by the truster itself is the shares itself, it cannot be readily concluded that the first sale of shares, even if the shares were again purchased under title trust without the first sale of shares.

(5) As to the allegation of illegality in calculating the gift value

(A) As to the assertion that the calculation of the gift price based on the market price formed at an abnormal market price manipulation was lawful, it cannot be concluded that the market price of each of the instant shares has increased as a result of the following: (i) price manipulation was conducted; (ii) price manipulation was conducted; (iii) price of each of the instant shares can be deemed as an objective exchange price since the market price was freely traded between many and unspecified persons; and (iv) the Plaintiffs could have purchased and sold each of the instant shares according to the market price formed at the time of stock market; and (iii) even if the market price was formed by a stock price manipulation, it cannot be concluded that the Plaintiffs who offered such cause against the principle of good faith could not be found that the market price at that time was abnormal.

Therefore, the plaintiffs' above assertion is without merit.

(B) As to the assertion that the market price of shares issued with new consideration is either the payment date of shares or the transfer date, Article 41-2(1) of the Inheritance Tax and Gift Tax Act provides that the title holder shall be deemed to have donated the value of the property to the actual owner on the date when the actual owner registers, etc. as the title holder is different. Article 60(1) of the Inheritance Tax and Gift Tax Act provides that the value of the property shall be based on the current market price as of the donation date. ② Even if the subscription price of new shares is paid with the subscription price on the date of payment of the subscription price, the number of shareholders cannot be deemed the same as the date when the subscription price of new shares is registered, even if it is possible to oppose the company because the subscription price of new shares is paid with the subscription price due to the subscription price payment date, the acquisition price of new shares cannot be deemed to have been calculated on the basis of the market price of 000 under the Act, and the acquisition price of new shares cannot be deemed to have been calculated on the basis of 1000th of the transfer price of shares issued.

Therefore, the above argument of the plaintiffs is reasonable (the calculation of legitimate tax amount with respect to this is examined in the following (7)).

(6) As to the assertion that the requirements for deemed donation due to the sale of shares before the transfer of ownership are not satisfied

“The provision on deemed donation of trust property under Article 41-2(1) of the Inheritance Tax and Gift Tax Act applies to the case where the actual owner and the nominal owner are different from the property that requires the transfer or exercise of the right. In the case of registered shares, unless a change of ownership is made in the name of another person who is not the actual owner of the shares, it cannot be deemed that the above requirement under Article 41-2(1) of the Inheritance Tax and Gift Tax Act has been met (see, e.g., Supreme Court Decision 2005Du10200, Sept. 24, 2009); (1) Category DoD was included in the list of shares purchased under the Plaintiff’s name from October 17, 200 to November 21, 200; (2) 37BD shares issued under the name of the Plaintiff’s new shares purchased under the above 40BD shares; and (3) 40BD shares purchased under the name of the Plaintiff’s new shares purchased under the name of 20.

According to this, Dodddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddddd

Therefore, the evidence submitted by the Defendants alone is insufficient to recognize that the entry of the change of holders on December 31, 200 with respect to 85,094 shares acquired based on capital increase with a capital increase in the name of Plaintiff RedB, and there is no other evidence to acknowledge this otherwise. Therefore, it is reasonable to deem that the disposition of imposition (this tax) listed in the attached Table 1 No. 6 and the disposition of imposition (additional tax) listed in the attached Table No. 6 of the attached Table No. 21 committed by the Defendant HongB with respect to the above shares was unlawful.

(7) Calculation of a reasonable amount of tax

(A) Disposition of imposition against Plaintiff LA

(1) The imposition disposition listed in attached Table 1 No. 1 and the imposition disposition listed in Attached Table 2 No. 1 (additional tax)

"The head of Gangnam-gu Tax Office shall calculate the market price of 25,00 shares issued with capital increase on October 24, 200 to 1stA, and impose gift tax on 25,00 shares issued with capital increase on December 31, 200, by calculating the market price as OO members per share as of December 31, 200, but the value of donated shares as of December 8, 2000 by applying OO members (x25,00 shares), which is the appraised value as of December 8, 200. After calculating the value of donated shares as of December 1, 200, the head of this district tax office imposed a disposition of imposition (principal tax) No. 1 in the attached list No. 25,00 shares issued with capital increase on October 24, 200. Accordingly, the value of donated shares calculated by applying the correct list No. 2,00,000 shares to O2,000 shares issued with capital increase in the attached list No. 30.

"As of December 31, 2001, the head of Gangnam Tax Office issued a disposition of imposition (principal tax) listed in the [Attachment No. 1] No. 2 on the basis of the value of donated property calculated by evaluating 30,800 shares of CCC as the tax base of the Plaintiff LA as of December 31, 2001, and the head of Echeon Tax Department also issued a disposition of imposition (additional tax) listed in the [Attachment No. 2] No. 2 on the basis of the value of donated property assessed as the OOO per share. However, each of the above dispositions is the same as above. However, since each of the above dispositions was erroneous in the disposition of imposition (the taxable value less than 10 years added to the gift value in question) listed in the [Attachment No. 1] No. 1 in the annexed Table No. 2 list and the pertinent disposition of imposition (additional tax) as the tax base of the Plaintiff’s maximum amount of gift tax in the annexed Table No. 3 list, the legitimate amount of gift tax should be revoked from the previous list No. 201.

3. Disposition of imposition (main tax) listed in Attached 1 List 3 and disposition of imposition (additional tax) listed in Attached 2 List 3

"As of December 31, 2004, the head of Gangnam District Tax Office imposed 3 tax (principal tax) on the basis of the value of donated property calculated by evaluating 10,837 shares of CCC as an OOOO member per share as of December 31, 2004, and the head of EOcheon Tax Office also imposed 3 tax (additional tax) on the basis of the attached list No. 1. However, each of the above dispositions was erroneous in the imposition disposition listed in the attached list No. 1 and the attached list No. 2 (additional tax) and the imposition disposition (additional tax) listed in the attached list No. 2 (additional tax) as of December 31, 204. If this part is revised at a correct price, the legitimate amount of gift tax should be the same as the previous principal tax as the one mentioned in the attached list No. 3 list No. 1, 2004, and thus, the part exceeding the amount of the above list No. 3000 (O and additional tax).3).

(4) Disposition of imposition (main tax) listed in Attached Table 1 No. 4 and disposition of imposition (additional tax) listed in Attached Table 2 No. 4

"As of December 31, 2005, the head of Gangnam District Tax Office issued a disposition of imposition (principal tax) listed in attached Table 1 No. 4 on the basis of the value of donated property calculated by evaluating 30,648 shares of CCC as an OOOO for each share as of December 31, 2005, and the head of EOcheon Tax Office also issued a disposition of imposition (additional tax) listed in attached Table No. 2 List No. 4 on the basis of these facts. However, each of the above dispositions was erroneous in the disposition of imposition (principal tax) listed in attached Table 1 No. 3 and the disposition of imposition (additional tax) listed in attached Table 3 No. 2 List No. 3 as of December 31, 2005 as of December 31, 2005, the legitimate amount of gift tax should be the same as the previous principal tax, and the portion exceeding the amount of the original tax, OO, 2005.

(B) Disposition of imposition against Plaintiff HongB

(5) Disposition of imposition (main tax) listed in Attached 1 List 5 and disposition of imposition (additional tax) listed in Attached 2 List 5

"Each of the above dispositions made by the defendant HongB against the plaintiff HongB" shall be legitimate as stated in the item for re-calculated amount of the gift tax on October 24, 2000 by the plaintiff HongB among the details for calculation of legitimate amount of tax in attached Table 3," and vi) the imposition disposition listed in attached Table 6 No. 1 No. 6 (this tax) and the imposition disposition (additional tax) listed in attached Table 6 No. 2 No. 52

As seen above, each of the above dispositions against the Plaintiff HongB by the Defendant HongB should be revoked as it is unlawful.

(8) Sub-determination

따라서 이 사건 각 처분 중, ① 원고 최AA에게, ㉠ 피고 강동세무서장이 한 별지 제1 목록 순번 1 기재 부과처분 중 OOOO원을 초과하는 부분, ㉡ 피고 이천세무서장이 한 별지 제2 목록 순번 1 기재 부과처분 중 OOOO원을 초과하는 부분, ㉢ 피고 이천세무서장이 한 별지 제2 목록 순번 2 기재 부과처분 중 OOOO원을 초과하는 부분, ㉣ 피고 이천세무서장이 한 별지 제2 목록 순번 3 기재 부과처분 중 OOOO원을 초과하는 부분, ㉤ 피고 이천세무서장이 한 별지 제2 목록 순번 4 기재 부과처분 중 OOOO원을 초과하는 부분을 각 취소하여야 하고, ② 피고 용인세무서장이 원고 홍BB에게 한 별지 제1 목록 순번 6 기재 부과처분과 별지 제2목록 순번 6 기재 부과처분을 각 취소하여야 한다.

3. Conclusion

Therefore, the plaintiffs' claims shall be accepted within the scope of the above recognition, and each of the remaining claims shall be dismissed without merit, and the judgment of the court of first instance, including the claims that have been changed in exchange for exchange in the trial, shall be modified as above. It is so decided as per Disposition.