All appeals are dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Case summary

A. From around 1985 to December 1999, Plaintiff A acquired 3,159,320 shares of Company D (hereinafter “D”) from around 1985 to title trust in the name of C.

B. A around 2007, C requested the Plaintiff A to adjust the title of the shares.

Accordingly, on December 29, 2007, Plaintiff A changed the name of shares in the form of donation made by C to Plaintiff A on December 29, 2007, in the form of donation made by C to the Plaintiff. The remaining 894,622 shares (hereinafter “instant shares”) was changed in the form of donation made by C to Plaintiff B.

C. On March 29, 2008, Plaintiff B reported gift tax on the grounds of “the Plaintiff B donated the instant shares from C on December 29, 2007,” and paid KRW 14,427,913,173 among the instant shares as KRW 391,351 out of the instant shares on July 7, 2008 upon the Defendant’s permission for payment in kind.

On May 25, 2009, the Defendant assessed the value per share of the instant shares as KRW 40,051, and notified the Plaintiff B of the increase in gift tax.

(hereinafter “instant first disposition”). E.

On November 1, 2013, the Defendant revoked the instant first disposition and returned 391,351 shares paid in kind by the Plaintiff B to the Plaintiff A.

F. On the same day, pursuant to Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter the same), the Defendant: (a) deemed the Plaintiff A as the donor; and (b) evaluated the value per share of the instant shares as KRW 60,453; (c) assessed the value per share of the instant shares as KRW 26,581,291,883; and (d) issued a joint payment order by notifying the Plaintiffs of KRW 10,632,516,753; (d) additional tax of KRW 10,632,516,753; (e) additional tax of KRW 16,315,59,957; and (e) ordering joint payment.

"Imposition of gift tax, etc. of this case" in all the following amounts: