1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. On August 30, 2012, the Plaintiff’s mother opened a securities account under the name of the Plaintiffs, and transferred 8,210 shares of D Co., Ltd. (hereinafter “instant shares”) under the name of the Plaintiffs to 4,105 shares, respectively.

B. On March 27, 2014, the Defendant sent C a notice of return and payment after the deadline for capital gains tax on the reduction of the number of stocks, and C submitted a return after the deadline for capital gains tax on April 24, 2014, with the transfer value of KRW 13,829 per share, and KRW 13,863 per acquisition value.

C. The Defendant conducted a tax investigation on the instant stock transaction between the Plaintiffs and C, and confirmed that the instant stock transaction was a gift, and assessed the instant stocks as KRW 37,078 per share, and notified the Plaintiffs of each gift tax of KRW 25,863,310 on July 10, 2015.

The Plaintiffs appealed and filed an appeal with the Tax Tribunal on August 4, 2015, but the Tax Tribunal dismissed the said appeal on December 16, 2015.

[Ground of Recognition] Facts without dispute, Gap evidence 1-1, 2, 2-1, 2-2, Gap evidence 3-1, 2-2, Gap evidence 4-1 through 6, Gap evidence 5, Gap evidence 6-1, 2, Gap evidence 7-1 through 3, Gap evidence 9-1, 2, and Eul evidence 1 through 5, the purport of the whole pleadings, and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. 1) The Plaintiffs’ assertion 1) C transferred the instant shares held since 2003 under the name of the Plaintiffs by stealing the name without relation to the Plaintiffs’ intent, which is their children, through the solicitation of the securities company’s employees, due to the difficulties in market transaction. Moreover, as the Plaintiffs are minors, the Plaintiff, who is a person with parental authority, unilaterally transferred the instant shares, is null and void as it constitutes the act of this maritime conflict, and there was no purpose of tax avoidance. 2) The Defendant has the value of the instant shares as a supplementary assessment method.