Plaintiff 1 and 14 others (Attorney Lee Jong-ho, Counsel for the plaintiff-appellant)

Goyang Tax Office and 4 others (Law Firm Rate, Attorney Cho Young-sik, Counsel for the plaintiff-appellant)

July 20, 2005

Seoul Administrative Court Decision 2004Guhap18085 decided Dec. 16, 2004

1. All appeals by the Defendants are dismissed.

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

1. Purport of claim

The Defendants gather each gift tax imposition disposition against the Plaintiffs as shown in the separate sheet of imposition.

2. Cancellation

2. Purport of appeal

The judgment of the first instance is revoked. All of the plaintiffs' claims are dismissed.

1. Quotation of judgment of the first instance;

The reasoning of this Court’s reasoning in this case is as follows: (a) other than the correction of “1,401,780 won (total estimated sale price of KRW 1,686,342,00 ± total sale price of KRW 1,203 ± the total sale price of KRW 1,203 ± the grounds for the judgment of the first instance; and (b) other than the correction of “1,686,342,00 won” among the grounds for the judgment of the first instance; and (c) therefore, (d) pursuant to Article 8(2) of the Administrative Litigation Act; and

2. Conclusion

Therefore, the judgment of the first instance court is justified, and it is so decided as per Disposition by the defendants.

[Attachment List of Imposition]

Judges Lee Sung-sung (Presiding Judge) (Presiding Judge)