1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

The reasoning of this court's judgment is as follows, except for the dismissal of the following matters among the judgments of the court of first instance, and therefore, it is accepted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. At the last seven pages, the phrase “(the shares in this case were 84,000 shares free of charge on June 2008)” shall be added.

7. The last 7th "loan" or "Do Lease" shall be changed to "Do Lease".

10. The 17th parallel "C" to the 11th parallel "at the time of dismissal" shall be as follows:

【C has resolved a title trust in only one year, and there was no dividend income to be additionally avoided; C was in the position of oligopolistic shareholders regardless of title trust; C was not only in the position of oligopolistic shareholders, but also in the position of the instant shares, so there is no room to avoid secondary tax liability or deemed acquisition tax due to the acquisition of unlisted shares; securities transaction tax imposed on the transaction of listed shares is 0.5%, regardless of who is the nominal owner of the instant shares; and the securities transaction tax to be avoided is not possible regardless of whether the nominal owner of the instant shares is the nominal owner; and as the instant shares were returned from the Plaintiff’s name to the Plaintiff’s name, and thus, C did not have any capital gains tax avoided; and C appears to have acquired the instant shares under the Plaintiff’s name for the purpose of protecting management rights; and in light of this, C appears to have acquired them from the Plaintiff to sell the instant shares at a price including management rights premium, which would have been likely to have been avoided before the sale of the instant shares to the third party.