All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1. As to the ground of appeal No. 1, Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007) (hereinafter “the legal provision of this case”) provides, “Where the actual owner and the nominal owner are different from any other property (excluding land and buildings; hereafter the same shall apply in this Article), the value of the property shall be deemed to have been donated to the actual owner by the nominal owner on the day (where the property requires a transfer of ownership, referring to the day following the end of the year following the year in which the date of acquisition of ownership falls) on which the actual owner and the nominal owner are registered as the nominal owner, notwithstanding Article 14 of the Framework Act on National Taxes: Provided, That the same shall not apply to cases falling under any of the following subparagraphs:

In light of the circumstances stated in its reasoning, the lower court determined that the instant disposition was lawful on the ground that it is reasonable to view that Plaintiff B was the title trust of the instant shares to Plaintiff B, and that the instant title trust was made for a clear purpose that is irrelevant to tax avoidance, and that it cannot be deemed that there was no tax avoided through the instant title trust or that it was merely a minor reduction of tax.

Examining the record in light of the aforementioned provisions and relevant legal principles, the above determination by the lower court is justifiable, and contrary to what is alleged in the grounds of appeal, the lower court did not err by exceeding the bounds of the principle of free evaluation of evidence in violation of logical and empirical rules, or by misapprehending the legal doctrine

2. As to the second ground for appeal, the legal provision of this case is against the substance over form principle.