The claim shall be dismissed.

from 00.00.000 to 17,700 per share of 270,000 shares of 000

Pursuant to the premise that the acquisition by transfer of 5,000 won per share was made by the purchase, the Plaintiff first 00

The First Disposition asserts that it is unlawful.

According to the statements in Gap 22, Gap 23-1, 2, and 33-1, 2, and Eul 21, the plaintiff

00 The loan claims against 000 representative director, 000

Along with 00, 000 shares forfeited from the second subscription for new shares 000 shares that have been forfeited

of 000 shares 27,000 shares held by the Corporation was transferred to the Plaintiff 000 shares.

c. 00 00 1.35 000 million won in payment in kind with 000 shares

of 5,000 won per share for a stock transaction between the plaintiff 00

tax authority shall investigate the change of the shares of the Plaintiff 000.

assessment of 17,777 won, not per share 5,000 won per share in the process, and 00

(1) the fact that a revised transfer income tax was reported and that it was demanded to additionally pay underpaid portion;

00 The transfer value per share of 17,777 won and the transfer value per share of 5,000 won.

for the difference of the corporation, a revised transfer income tax return shall be filed and all tax amounts equivalent to the difference shall be paid.

The facts so established may be recognized.

However, in full view of the purport of the entire pleadings in Eul evidence No. 22, the plaintiff 000

shares from 000 upon receipt of an investigation by the regional tax office with respect to the investigation of gift tax on

immediately before acquiring the Corporation, 000, 244,933 Shares 16,31 per share, aggregate of 4 billion won

purchase at source, and 270,000 per share, total of 1,350,000 won per share.

The acquisition by transfer has been made from the above 0000 to the above 16,331 won per share between individuals.

of KRW 5,00 per share from 00 to KRW 17,777,00 per share because it does not fit the words;

It can be recognized that the person has made a false statement in the purchase, and that such a statement has been made.

Plaintiff 00’s total of KRW 5,000 per share of KRW 270,000 from the date of new boarding 13

Since the plaintiff 00 million won was transferred to 50 million won, the above argument by the plaintiff 000 is without merit.

○ In Part 15 of the first instance judgment, the following additions are made as follows in Part 14:

The legislative purport of Article 45-2(1) of the Inheritance Tax and Gift Tax Act is the Tax Association using the title trust system.

The substance over form principle to the purport that tax justice is realized by effectively preventing the act of avoidance.

Since exceptions are recognized, the purpose of the title trust does not include the purpose of tax avoidance.

(1) The proviso to paragraph (1) of the same Article shall apply only if it has not been subject to tax avoidance.

The burden of proof on this point is against the person who asserts it (Supreme Court Decision 99 delivered on July 23, 199).

Supreme Court Decision 2192; Supreme Court Decision 2003Du13649 Decided December 23, 2004; etc.) also owns real ownership

The presumption of donation is based on the fact that the nominal owner has no purpose of tax avoidance.

No provision shall be avoided (see Supreme Court Decision 2004Du1421, Jun. 11, 2004).

○ Removal from the 15th judgment of the first instance court up to the 17th to the 18th judgment.

2. Conclusion

Therefore, the judgment of the court of first instance is justifiable, and it is so decided by the plaintiff 000,000,000

The appeal by the director of the tax office and the defendant 000's appeal are dismissed for all reasons.

2. Of the appeal costs, the part arising between Plaintiff 10.00.000.000 and Defendant 1000, 000, 000, and 00 shall be borne by the above Plaintiffs; the part arising between Plaintiff 100 and Defendant 100, respectively, by the head of the above tax office.

Each disposition taken by the Defendants in the separate sheet against the Plaintiffs shall be revoked.

2. Purport of appeal

A. Plaintiffs 00.00.000.000.000

The part against the above plaintiffs in the judgment of the court of first instance shall be revoked. Defendant 000,000,

00 The head of the tax office shall revoke all of the imposition dispositions listed in the separate sheet against the above plaintiffs.

B. Defendant 00 director of the tax office

The part against the director of the tax office of 000 among the judgment of the first instance shall be revoked, and the revocation part shall be revoked.

The court's explanation on this case is consistent with the reasoning of the judgment of the court of first instance, except for dismissal, addition, or deletion as follows. Thus, the court's explanation on this case is accepted in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

○ Part 8 of the 8th judgment of the first instance court “illegal” added the following (see Supreme Court Decisions 2016Du52637, Dec. 29, 2016; 2015Nu58029, Aug. 17, 2016; 2015Nu58029, Aug. 17, 2016) to “00” under the 8th judgment of the first instance court under the 9th judgment of the first instance court.

○ On the 9th judgment of the first instance court, the following shall be added: