1. All appeals filed by the plaintiffs are 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 reasons why the court should explain in this judgment are as stated in the reasoning of the judgment of the court of first instance other than the following "paragraph 2" (Provided, That the part of the joint plaintiffs who did not appeal other than the plaintiffs of this case among the joint plaintiffs of the judgment of the court of first instance is excluded), Article 8 (2) of the Administrative Litigation Act, and the main text of Article 420 of the Civil Procedure Act.

2. Parts to be dried;

(a) The 4th 10th 10th 10th 1 of the judgment of the first instance court was written “Plaintiff I” with “Plaintiff I”.

B. In light of the fact that it is not necessary to determine whether the aforementioned tax was evaded or not, the evidence submitted by the Plaintiffs alone does not necessarily determine whether the aforementioned portion was evaded or not. In full view of the above legal principles and comprehensive view, the evidence submitted by the Plaintiffs and the circumstances surrounding the evidence submitted by the Plaintiffs are considered, even if considering all the evidence submitted by the Plaintiffs and its assertion.

C. The 8th sentence of the first instance court's decision "Therefore, the plaintiffs' assertion is without merit." Therefore, the plaintiffs' assertion is without merit.

Meanwhile, the Plaintiffs may argue that the provision on deemed donation of title trust property under the Inheritance Tax and Gift Tax Act, which falls under the provisions on the basis of the instant disposition, violates the principle of proportionality and the principle of excessive prohibition. However, the above provision recognizes exceptions to the principle of substantial taxation in order to realize tax justice by effectively preventing the tax avoidance act using the title trust system. As such, the public interest is remarkably larger than the property disadvantage suffered by the title trustee due to the imposition of gift tax, and the imposition of gift tax under the above provision is reasonable in an appropriate way to realize the equity of tax justice and tax.

(c).