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

The purport of the claim and appeal is the purport of the appeal.

가. C 주식회사(이하 ‘C’이라 한다, 변경 전 상호는 L 주식회사이다)는 2001. 5. 17. 토목건축공사업 등을 목적으로 설립된 회사이다.

B. On April 28, 2009, Plaintiff B acquired shares 228,000 shares, etc. issued by C from D and E, and transferred them to KRW 280,000,000 for acquisition price. From June 15, 2009, Plaintiff B transferred the entire title trust from June 15, 2009 to another person including Plaintiff A, etc., and the details are as listed below.

Plaintiff A 47,880 Plaintiff A 54,720 Plaintiff A 54,720 Plaintiff A 54,720 C’s 47,880 F 47,880 G 41,040 G 41,040 G 41,040 G 41,040 G 43,320 H 84,360 H 140 H 41,040 G 0,040 I 0 I 0, J 00 J 0 J 84,360 C’s 228,200 total of 228,000 C’s 200,200,000

C. The Director of the Gwangju Regional Tax Office conducted a tax investigation on C, etc. from June 29, 2017 to August 7, 2017, and confirmed that C’s shares are in title trust, and notified the result to the Defendant.

Accordingly, on October 10, 2017, the Defendant imposed a gift tax of KRW 12,213,237 on Plaintiff A for the reason that the title trust of this case is deemed as a gift pursuant to the main text of Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter the same), and issued a notice of the designation of a joint and several taxpayer for the said gift tax (hereinafter collectively referred to as “instant disposition”). D.

Accordingly, the plaintiffs filed an appeal with the Tax Tribunal on March 28, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, 8, Eul evidence No. 1, the purport of the whole pleadings

2. The plaintiffs' assertion

A. On June 15, 2009, Plaintiff B held the title trust of 47,880 shares C with Plaintiff A around June 15, 2009 was made for the purpose of smooth operation of C, and there was no intention to evade taxes. The said title trust was made through the said title trust.