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

A. The Plaintiff A and his spouse, Plaintiff C, Plaintiff C, Plaintiff D, mother, Plaintiff E, and Plaintiff E, who are his spouse, held shares of Samsung Electronic Co., Ltd. totaling KRW 10,240,037,00 as of the end of 2011, and KRW 12,58,088,000 as of the end of 2012.

B. From 2012 to 2013, the Plaintiffs: (a) transferred the shares of Samsung Electronic Co., Ltd. (hereinafter “Tsung Electronic”); and (b) deemed that the transfer by a major shareholder under Article 94(1)3(a) of the Income Tax Act constitutes a transfer by a major shareholder; and (c) reported and paid capital gains tax and local income tax accordingly from June 2014 to August 2014, respectively.

C. The Defendants, as indicated in the attached Table 1, notified the Plaintiffs that no capital gains tax was notified, thereby imposing capital gains tax and local income tax as returned and paid by the Plaintiffs.

(2) Each disposition imposing capital gains tax (hereinafter referred to as "disposition imposing capital gains tax of this case" and each disposition imposing local income tax of this case in total shall be referred to as "the disposition of this case", and each of the above dispositions shall be referred to as "the grounds for recognition"). 【The fact that there is no dispute, Eul's evidence of subparagraphs 1 through 20 (including branch numbers; hereinafter the same shall apply), Eul's evidence of subparagraphs 1 through 8, Eul's evidence of subparagraphs 1 through 4, and the purport of the whole pleadings, each of the arguments

2. Making entries in attached Form 3 of relevant Acts and subordinate statutes;

[Article 157(4)2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013); Article 157(4)2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26982, Feb. 17, 2016); Article 157(4)2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26982, Feb. 17, 2016); and Article 3. Whether the instant disposition is legitimate

(a) whether it is a disposition based on an unconstitutional law;