All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1. Article 14(1) of the Framework Act on National Taxes provides, “If the ownership of the income, profit, property, act or transaction subject to taxation is merely nominal, and there is a separate person to whom it actually belongs, the person to whom it actually belongs shall be the person to whom it belongs as a taxpayer and to

The substance over form principle stipulated in Article 14(1) of the Framework Act on National Taxes, in cases where there is a person to whom such income, profit, property, transaction, etc. belongs, unlike the nominal person, is not the nominal person, but the person to whom such income, profit, property, or transaction, etc., belongs. Thus, in cases where the nominal person is unable to control and manage the property, and there is another person who substantially controls and manages it through control, etc. over the nominal person, and the disparity between title and substance arises from the purpose of tax evasion, the income on the property shall be deemed reverted to the person to whom the actual controlling and managing the property belongs, and the income on the property shall be deemed as attributable to the person to whom the income belongs. However, in cases where there is no disparity between

(2) On July 14, 2016, the lower court acknowledged the facts as indicated in its reasoning based on the evidence duly admitted by the lower court (see, e.g., Supreme Court Decision 2015Du2451, Jul. 14, 2016). In so doing, the lower court rejected the Plaintiffs’ assertion that each of the instant dispositions violated the principle of substantial taxation on the premise that the person to whom the transfer income of the instant new shares belongs is J and K, on the ground that the Plaintiffs, as the subject of investment and calculation with respect to the instant new shares, did not acquire the transfer income from the acquisition and transfer of the instant new shares merely on

. The above.