1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the court’s explanation concerning this case is as stated in the judgment of the court of first instance, except for the dismissal or addition of the text of the judgment of the court of first instance as follows. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

Under the second sentence of the judgment of the first instance, the second sentence " December 10, 2015" is "463,140,000 won per share" as "463,140,000 won," and the following is added under the first sentence of the judgment of the first instance, which is "463,140,000 won" as "463,140,000 won," and if the title truster is not specified, it is difficult to prove that the title truster is not subject to tax avoidance, the title trustee cannot be jointly and severally liable for tax payment that is deemed the donor, and it is impossible to confirm whether the deduction of donated property is applied to the truster who is deemed the donor, and thus, it is impossible to calculate the correct amount of tax. Thus, the defendant must always specify the title truster.

Article 45-2 (1) of the former Inheritance and Gift Tax Act only requires that “the actual owner and the nominal owner of the property that requires registration, etc. shall be different” and does not necessarily require that the actual owner be specified. In light of the legislative intent of the above provision, etc., even in cases where a title truster is not specified as an act of tax avoidance that interferes with the exercise of the State’s right to impose taxes by making it unclear the actual owner of the property right, etc., it shall be interpreted that gift tax may be imposed

As long as the title trust is revealed, even if the title truster is not specified, there is no difference between the cases where a specific title truster is revealed in the possibility of criticism that the title truster had committed the act of tax avoidance, and if so, the title truster is specified.