1. Revocation of a judgment of the first instance;

2. On July 28, 2015, the transfer income tax reverted to each of the Plaintiffs, each of which belongs to the year 2008.

1. The reasons why this court should explain concerning this part of the reasons for the disposition are the same as the part concerning the pertinent part of the judgment of the court of first instance from the second to the third to the second to the third to the 21st, and the 1. "The reasons for the disposition". Thus, this court shall accept it in accordance with Article 8(2) of the Administrative Litigation Act, the main text

2. Whether the disposition is lawful;

A. The reasoning of this court regarding this part of the plaintiffs' assertion is as stated in the corresponding part of the judgment of the court of first instance (as to the 4th to 2th, 11th, hereinafter "the part concerning the plaintiffs' assertion"), and therefore, it shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the

B. Determination 1) The former Framework Act on National Taxes (amended by Act No. 13552, Dec. 15, 2015; hereinafter “Act”)

Article 45-2 (2) provides that " Any person who has filed a return on a tax base by the statutory deadline for filing the return, or who has the tax base and amount of national taxes determined may request the determination or correction within two months from the date on which he/she becomes aware that the cause falling under any of the following subparagraphs has occurred," and subparagraph 1 of Article 45-2 provides that "any transaction or act, etc. which forms the basis for the calculation of the tax base and amount of tax in the initial return, determination or correction (hereinafter referred to as "the first return, etc.") shall include any reconciliation or other act

subsection (1) of this section provides that "when it has become final and conclusive."

The purport of the ex post facto request for correction is to expand the protection of taxpayers' rights by allowing taxpayers to file a request for reduction in cases where there is a change in the basis for calculating the tax base and the amount of tax due to the occurrence of a certain subsequent cause after the establishment of the tax liability. In this context, the "transaction or act, etc. under Article 45-2 (2) 1 of the Act among the grounds for ex post request for correction" refers to the transaction or act, etc.