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 grounds for this judgment by the court of first instance shall be as follows, with the exception that part of the judgment by the court of first instance is amended as follows:

Therefore, it shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007) provides that “The purpose of this Act is to effectively prevent the actual owner of property from doing the title trust act that only the name of another person for the purpose of tax avoidance and realize the tax justice by effectively preventing the title trust act that is held in the name of another person for the purpose of tax avoidance. Therefore, if it is recognized that the title trust act was conducted for another purpose than the purpose of tax avoidance and that only the incidental reduction of taxes arises, such act of title trust cannot be deemed as a donation, deeming that there was the purpose of tax avoidance. However, in light of the legislative purport as seen above, if it is deemed that the purpose of tax avoidance was not included in the purpose of the title trust, it shall not be deemed that the act of title trust act was deemed as a donation. In this case, the burden of proving that there was no other purpose of tax avoidance exists the title holder who asserts it (see, e.g., Supreme Court Decision 2012Du7171, Sept. 27, 217, 2017.

The five pages 8 of the first instance court's 5 pages "22" shall be changed to "2 and 25 evidence", and the five pages 9 "corporate tax, etc." shall be added to "at the time of the act of title trust (individual transfer) or "at the time of separate transfer".

The 5th sentence of the first instance court is 5th sentence, and the 5th sentence of the 19th sentence is 19th sentence, and the 5th sentence is 19th sentence, and it is reasonable to deem that the Plaintiffs, the nominal owner of the shares of this case, failed to bear the burden of proving that there was no tax avoidance purpose.”