2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1...

A. The reasons why the court should explain this part of the judgment of the court of first instance are as follows: each “F share dividend” in Part 3, No. 13, No. 17, and No. 42 of the judgment of the court of first instance, each “F share sales price” in Part 3, No. 17, and No. 42 of the judgment of the court of first instance, “F share transfer” in Part 4 is as “F share dividend (in form, dividends are paid from F, but actual D share sales price is paid in proportion to F share ratio)”, and the 3 through No. 5 are as follows, set forth in Part 4 below.

Inasmuch as the corresponding part of the judgment of the court of first instance is the same as the statement of reasons for the corresponding part of the judgment, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

B. Parts in height

I. The Tax Tribunal rendered a decision to conduct a reinvestigation to the effect that the plaintiffs should re-examine whether they received cash donation from C at the time of acquiring the shares under the names of the plaintiffs to rectify their tax base and tax amount.

(j) On June 2014, according to the purport of the reinvestigation decision, the Defendant decided to notify the Plaintiff B of the initial tax assessment based on the constructive gift of title trust with respect to the donation of stocks within the scope of maintaining the identity of the disposition, by changing the reason for disposal as cash donation of the acquisition fund of stocks within the scope of maintaining the identity of the disposition. As to the donor C, the Defendant revoked the designation of joint and several tax liability and

(k) On June 19, 2014, Plaintiff B and C demanded that Plaintiff B transfer the refund corresponding to the amount of gift tax payable by Plaintiff B among the national tax refund of Plaintiff C, and Plaintiff B demanded on June 24, 2014 that the national tax refund be appropriated for the gift tax levied on him/her.

(l) On June 25, 2014, the Defendant, without changing the tax items, tax bases, and amount of tax, stated that “the grounds for the original tax disposition shall be changed by cash donation for acquisition of stocks within the scope recognized as identical to the original tax disposition.”