2. The costs of appeal are assessed against the Plaintiffs.

This court's decision is cited in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, since it is identical to the reasoning of the court of first instance, except for the dismissal of part of the judgment of the court of first instance and addition of the judgment under paragraph (2).

○ 2 side 8 side 8 side 8 side 2 (hereinafter referred to as “HHA”) is called “HHA” (hereinafter referred to as “HHA”).

○ 4 3 pages 4, "No time has been available for making a dividend," is the same as "no fact has been available for making a dividend."

○ 5 pages 4, “Transfers were sent,” and “the content of the transaction is indicated as ‘stock price’ in the column.”

The term "***************)" of the five pages 5 side 5 side 5 side 5 side 5 side 5 side ***** bank (*******).

○ 5. 6. The following shall be added to 6.

6) In the tax investigation conducted on December 24, 2014, Plaintiff (B) stated that the transfer form of the nominal shares was equal to the face value of the shares, based on the advice surrounding that it would create a financial basis for the transfer of the nominal shares, as to the reasons that the shares transferred to Plaintiff (A) from the tax investigation conducted on September 5, 2011, and that the said shares were transferred to Plaintiff (B) and that the said shares were transferred to Plaintiff (B). Plaintiff A reported transfer income tax while transferring the instant shares to Plaintiff B.

"No. 11 and No. 12" shall be added to the 5th 7th 7th 8th mar [based on recognition].

○ 6th 8th 7th 6th 7th 6th 7th 8th 6th 6th 8th 1st 6th 6th 6th 6th 6th 6th 6th 6th 10

○ 6th page 13 "on the main place" is "on the main place".

○ 7 pages 1, “The fact that it was in possession” is as follows:

In addition, there was a separate security other than the instant shares, and the Plaintiff (BB) could actually receive part of the earned surplus of HHHH as a controlling shareholder of HHHA with thisCC, and Plaintiff (BB) did not have any legal impediment in acquiring the instant shares in its own name and providing them as a security.

○ 7 pages 3 add the following contents to 4, 7, and 12 others, and 3. 4, 7, and 12. 5.

③ On September 5, 2011, Plaintiff B’s transfer of KRW 60 million to Plaintiff A’s account, stating the details of the transaction as “stock price” is merely deemed to have been based on the appearance of a normal stock transaction at the time of returning the nominal trust shares to the total par value of the shares, and thus, it is insufficient to serve as the ground for the Plaintiff BB’s borrowing of the funds from Plaintiff BB’s account.

④ If Plaintiff A had the title of ownership of the instant shares for the purpose of collateral security, and the said shares were transferred to Plaintiff BB, the actual owner, to return the shares, the instant shares are merely a collateral, and thus, the transfer income tax was reported, even though it does not need to report the transfer income tax.

○ 10 pages 22 shall be added to the Acts and subordinate statutes stated in the attached Form "Additional Parts of the Acts and subordinate statutes."

2. Additional determination

A. Summary of the plaintiffs' assertion

The tax investigation conducted prior to the disposition of this case was temporarily suspended immediately before the expiration of the investigation period without any reasonable explanation to the plaintiffs, and the investigation period was unfairly extended. As such, the disposition of this case, which was conducted based on unlawful tax investigation under the procedure as above, was unlawful.

B. Determination

According to Article 81-8(1) and (4) of the Framework Act on National Taxes, a tax official shall set the tax investigation period at a minimum, but where it is difficult to conduct a tax investigation due to the reasons prescribed by Presidential Decree, a tax official may suspend the tax investigation, and Article 63-10(3) of the Enforcement Decree of the same Act provides for the cases where it is difficult to conduct a tax investigation normally under each of the following subparagraphs: (a) through (d) the specific reasons such as where the taxpayer's whereabouts is unknown; and (e) the cases where there are other similar reasons.

Article 14-1 through 4 of evidence Nos. 16, and Article 15 of the Evidence Nos. 14-1 through 15 of the Criminal Procedure Act provides that according to the purport of the whole pleadings, the commissioner of the Regional Tax Office shall determine the period of the tax investigation to the Plaintiffs from November 15, 2014 to January 8, 2015 and notify the Plaintiffs of the tax investigation, and shall proceed with the tax investigation on January 7, 2015; and shall, during the period from January 7, 2015 to January 28, 2015, notify the Plaintiffs of the suspension of the tax investigation by determining the period of the tax investigation as "any other cause which is difficult to normally proceed with the tax investigation"; and on January 27, 2015, the commissioner of the Regional Tax Office may recognize the difference between the taxpayer's opinion and the taxpayer's opinion to suspend the tax investigation from January 27, 2015 to January 27, 2015.

Examining the above facts in light of the above Acts and subordinate statutes, there is no significant procedural error in the tax investigation conducted prior to the disposition of this case to the extent that the illegality of the disposition of this case is affected. The plaintiffs' above assertion is without merit.

3. Conclusion

The judgment of the first instance is justifiable. The plaintiffs' appeals against the defendant are all dismissed.