A. F Co., Ltd. (hereinafter “F Co., Ltd.”) was established on February 22, 198, and changed its trade name to “G Co., Ltd.” on January 4, 1993, and H Co., Ltd. (hereinafter “H”) changed its trade name on April 1, 2006 to J Co., Ltd.

On May 27, 2000, the trade name was transferred to "I Co., Ltd." and on April 1, 2006, respectively, changed to "J Co., Ltd."

B. On March 31, 2005, the Plaintiffs, K, and L transferred the instant company’s shares (hereinafter “instant shares”) to M, N, andO (hereinafter “transferees”) at 10 won per share.

The transferee’s shares (owner’s shares) Plaintiff A 515,491 5,154,910 Plaintiff C 412,393 4,123,930 Plaintiff D 613,623 6,136,230 K 412,393 4,123,930,930 Plaintiff E 108,0661,080,660 N 871,367 8,713,670 B 128,8731,288,730 L546,235,462,350 O1,953,900,539,000

C. According to Article 63 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 7580, Jul. 13, 2005; hereinafter “former Inheritance Tax and Gift Tax Act”), the Defendants assessed the value of the shares of this case as 2,898 won per share (M and N shall be 3,767 won per share plus 30/100), and determined that the Plaintiffs unfairly reduced the tax burden on capital gains in transactions with the related parties, the Defendants’ head of the defendant Sejong District Tax Office imposed capital gains tax of 475,30,330 won for the Plaintiff on May 4, 201 (including 185,335,620 won), capital gains tax of 507,902,580 won for the Plaintiff C, of 205, of 205, of 305 capital gains tax of 205, of 305 capital gains tax of 2506, of 2015, including additional tax of 2501, 7.5