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

C Co., Ltd. (hereinafter “C”) is a company established on January 12, 1990 for the purpose of general books and textbooks publishing business, wholesale and retail business, etc.

D, who served as a joint representative director, transferred on November 15, 2004, 60,000 shares of C owned by himself (hereinafter “instant shares”) to C’s officers and employees including the Plaintiffs, and completed the transfer of ownership.

The Defendants applied Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”) on the grounds that the Plaintiffs received title trust of the instant shares from E, the actual owner of the C, thereby notifying the Plaintiff of the imposition of gift tax amounting to KRW 9,205,880 (including additional tax) on April 1, 2015, and the director of the tax office of the Incheon District Tax Office (including additional tax) on March 17, 2015.

(hereinafter “instant disposition”). The Plaintiffs were dissatisfied with the instant disposition and filed an appeal with the Director of the Tax Tribunal on April 20, 2015, but the said appeal was dismissed on August 12, 2015.

[Grounds for recognition] The facts without dispute, Gap evidence Nos. 1, 2, 11, Eul evidence Nos. 1, 11, and 17 (including a serial number; hereinafter the same shall apply), and the purport of the entire pleadings as to whether the disposition of this case is legitimate or not, the plaintiffs asserted that the shares of this case were held in trust by a F religious organization, not an individual E. The F Religious organization is exempt from custom profit-making business as a religious organization, and it has no purpose of tax avoidance.

F Religious organizations held in trust the shares of this case to the Plaintiffs, the believers, for reasons such as question whether religious organizations may become shareholders of C who conduct profit-making business, concerns that C or its executives and employees may suffer disadvantages when they become a legal entity operated by F Religious Organizations, and raising awareness of believers’ self-esteem, etc., and held in trust various companies, including C, in the same manner.