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 reasoning for this part of this Court’s reasoning is that the corresponding part of the judgment of the court of first instance is identical to that of the judgment of the court of first instance, thereby citing it as it is in accordance with the text

2. The assertion and judgment

A. The reasoning for this decision is that this part of the judgment of the court of first instance is identical to the corresponding part of the judgment of the court of first instance, except for the modification of Defendant B’s “Defendant B” as “Plaintiff B,” and thus, this part of the judgment is cited in accordance with the main sentence of Article 420 of the Civil Procedure Act.

B. 1) The summary of the Plaintiffs’ assertion that the disposition imposing gift tax of this case is null and void for the following reasons. Accordingly, the Defendant must return the amount equivalent to the taxable value of each real estate of this case among the gift taxes paid by the Plaintiffs, and interest and delay damages thereon. (A) The Plaintiffs and E agreed to divide the profits accrued therefrom after conducting the housing site development business using the real estate of this case. Accordingly, E was transferred to the Plaintiffs who were in office as internal directors of FF Co., Ltd. (hereinafter “F”) in the form of onerous gift.

Therefore, the imposition of gift tax in this case is made on an invested property, not subject to the gift tax, and its defect is significant and apparent.

B. Even if each of the instant real estate cannot be considered as an investment property, E exercised the right to statutory rescission on the ground of the Plaintiffs’ nonperformance of obligation, and thus rescinding the gift tax liability for each of the instant real estate retroactively becomes null and void.

Therefore, the imposition of gift tax in this case is conducted against the non-tax payer, and the defect is significant and apparent.