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

A. C Co., Ltd. (hereinafter “Nonindicted Company”) is a company that runs a general book and textbook publishing business on January 15, 1990.

B. D, who served as the representative director of the non-party company on November 15, 2004, transferred 60,000 shares of the non-party company owned by himself to the officers and employees of the non-party company including the plaintiffs, and completed the transfer of ownership.

C. 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’ shares at issue were title trust by Nonparty Company E, the actual owner of the non-party company, and the head of the Gu-U.S. Tax Office determined and notified the Plaintiff of KRW 21,765,350 (including additional taxes) of gift tax on March 9, 2015, and the head of the defendant Nam Daegu Tax Office of Apr. 1, 2015, of KRW 6,005,920 (including additional taxes) respectively.

(hereinafter “instant disposition”) D.

The Plaintiffs were dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 20, 2015, but was dismissed on August 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 11, Eul evidence Nos. 1 and 11 (including additional numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiffs alleged that they were entitled to title trust by F Religious organizations, not E, but E. Since F Religious organizations are exempt from taxation of profit-making businesses in practice as religious organizations, there is no room for recognizing the purpose of tax avoidance.

However, the FM religious organization will be a shareholder of the non-party company who carries out profit-making business; the non-party company will be a corporation operated by the FM religious organization, and the non-party company or its officers and employees may suffer disadvantages when it comes to a corporation operated by the FM organization; and the new shares will be raised to the plaintiffs, who are the believers.