All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

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

1. One of the fictitious dividends under Article 17(2)1 of the Income Tax Act provides that “The value of money and other property acquired by a stockholder due to the retirement of stocks or reduction of capital, or the amount of money and the value of other property acquired by an employee or investor due to retirement or resignation or withdrawal from a company, or reduction of investment, exceeds the amount used by the stockholder, employee, or investor to acquire the stocks or investment,” and Article 46 subparag. 4 of the Enforcement Decree of the Income Tax Act, which provides for the receipt time of dividend income as delegated by Article 39(6), provides that “the date of receipt of the fictitious dividends under Article 17(2)1 of the Income Tax Act, as of the date on which the stock retirement, reduction of capital, or transfer of capital (referring to the date determined by Article 461(3) of the Commercial Act, in cases of a resolution of the board of directors) is determined”.

2. The lower court, based on its adopted evidence, concluded a contract under which (a) E Co., Ltd. (hereinafter “instant company”) and G acquire 4,909 shares (hereinafter “instant shares”) totaling KRW 210,00 per share of KRW 9,430,890 per share from the Plaintiffs, shareholders, and G, as of December 6, 200 following the resolution of the board of directors on December 6, 200; (b) paid the price in full on December 21, 200; (c) the instant company held a temporary general meeting of shareholders on September 27, 2010 to reduce its capital by retiring 44,909 shares without compensation; and (c) the Defendants completed the registration of the change of capital reduction on December 9, 2010 following the procedure such as public announcement.