1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The court's explanation of this case is identical to the reasoning of the judgment of the court of first instance except for the following cases. Thus, the court's explanation of this case is acceptable as it is in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

(1) In addition, the first instance court’s rejection of the Plaintiff’s assertion, even if both the evidence submitted in the first instance trial and the evidence submitted in this court are examined, the grounds alleged by the Plaintiff at the time of appeal are not significantly different from the contents alleged by the Plaintiff in the first instance trial, and the first instance court’s rejection of the Plaintiff’s assertion is justifiable).

A. The gist of the Plaintiff’s assertion was that the Plaintiff had adequate assets at the time of the instant title trust agreement, and there was no objective situation that is likely to obtain compulsory execution or provisional attachment disposition, and that the net B temporarily uses title trust for the purpose of education on decoration to the Plaintiff. Therefore, there was no intention to evade taxes or avoid restrictions under the proviso of Article 3-2 of the Enforcement Decree of the Real Estate Real Name Act to the Plaintiff.

However, the Defendant did not take into account the grounds for reduction of the penalty surcharge or abused discretion, thereby making the instant disposition.

The judgment of the court of first instance rendered a favorable judgment on June 3, 2015 on the ground that the title trust agreement of this case and the registration of each transfer of ownership of this case pursuant to the title trust agreement of this case are null and void pursuant to Article 4(1) and the main text of Article 4(2) of the Real Estate Real Name Act, and both the appellate court (Seoul High Court 2015Na2037403) and the appellate court (Supreme Court 2017Da208836) have maintained the same conclusion.

The evidence No. 8-1 through No. 12 of the first instance judgment of "A" is respectively included in the following parts through No. 5 of the first instance judgment of "A".