1. The defendant's appeal is dismissed.

2. The costs of the lawsuit after the appeal shall be borne by the defendant.

purport, purport, and.

1. The reasons why the court should explain this part of the disposition are as follows: (a) the court shall dismiss the “SPC” of the third party 11 of the judgment of the court of first instance as “E”; and (b) add “including” of the fourth party 17 and 18 to “including”; and (c) the same shall apply to the corresponding part of the judgment of the court of first instance as stated in the grounds. Therefore, this part of the judgment of the court of first instance shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Whether each of the dispositions of this case is legitimate

A. The gist of the Defendant’s assertion 1) The Plaintiff acquired the instant convertible bonds from D as to the instant disposition Nos. 1, which was based on Article 40(1)2(b) of the Inheritance Tax and Gift Tax Act, in relation to the instant disposition Nos. 2, 3, the Plaintiff acquired the instant convertible bonds from D as to the instant disposition. As such, each of the instant dispositions is lawful as it is based on Article 40(1)2(b) of the Financial Investment Services and Capital Markets Act (hereinafter “Capital Markets Act”).

B) Even if D, alternative securities (or E), and foreign exchange banks do not correspond to “takeover” under the Securities and Exchange Act or the Capital Markets Act, the Plaintiff unfairly reduced gift tax by means of D, alternative securities (or E), and foreign exchange banks in order to avoid gift tax to be borne when they directly acquire the instant convertible bonds and each of the warrant certificates. As such, each of the instant dispositions was lawful in accordance with Article 2(4) of the Inheritance Tax and Gift Tax Act, as Article 40(1)2(b) of the same Act applies to Article 40(4) of the same Act. Further, the Plaintiff obtained enormous profits from market price by exercising the instant convertible bonds and each of the warrant certificates, which constitutes a benefit under Article 42(1)3 of the Inheritance Tax and Gift Tax Act. Each of the instant dispositions is legitimate even under the aforementioned provisions.

2) The Plaintiff’s assertion D, E, and.