1. The plaintiffs' appeal is dismissed.

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

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

1. The reasoning of the court of first instance’s explanation concerning this case is as follows: (a) the reasoning of the judgment of the court of first instance is as stated in the reasoning of the judgment, except for the addition of the judgment as to the newly asserted matters in the trial of the court of first instance by the Plaintiffs; and (b) thus, (c) the same is cited by Article 8(2

2. Determination as to the newly asserted matters in the trial of the plaintiffs

A. The purport of the Plaintiffs’ assertion is that Article 39(1)1(c) of the former Inheritance and Gift Tax Act provides that “When a corporation issues new stocks at a price lower than the market price and thereby a person, other than the stockholders of the relevant corporation, obtains profits by directly obtaining the allocation of new stocks from the relevant corporation, the amount equivalent to such profits shall be deemed the value of donated property.” The comprehensive title (hereinafter “instant comprehensive provision”) under Article 39(1)1(c) of the former Inheritance and Gift Tax Act excludes cases where a stock-listed corporation or Association-registered corporation under the former Securities and Exchange Act allocates new stocks by means of securities offering method under Article 2(3) of the same Act within the scope of “distribution” as stated above, gift tax shall not be imposed even if a person who is not

Article 2 (3) of the former Securities and Exchange Act provides that "the public offering of new securities shall be made under the conditions as prescribed by the Presidential Decree," and Article 2-4 (1) and (4) of the former Enforcement Decree of the Securities and Exchange Act shall not be less than 50 persons who are solicited to make an offer to acquire new securities (paragraph (1) and (3) of the former Enforcement Decree of the Securities and Exchange Act shall be less than 50 persons in case where the number of persons who are solicited to make an offer to acquire new securities is less than 50 persons as a result of the calculation under the provisions of paragraph (3) of the same Article.