1. Each appeal by the Defendants is dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

1..

1. The reasons why the court is to use for this case are as follows: “Gift 1,604,113,500” (hereinafter “Gift 1,64,113,500) through the 3th, 7, and 8th, of the judgment of the court of first instance; and except for adding the following to the corresponding part, it is identical to the entry of the reasons for the judgment of the court of first instance; therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

(1) Article 42(4) of the former Inheritance and Gift Tax Act (amended by Act No. 42(4) of the same Act), which is one of the grounds for property value increase as provided in Article 42(4) of the same Act, means the listing by a merger as provided in Article 41-5 of the same Act. In conclusion, Article 42(4) of the former Inheritance and Gift Tax Act (amended by Act No. 42(4) of the same Act) means the listing by a donee of the relevant shares through a merger with another stock-listed corporation after the acquisition of the shares by the method as provided in each subparagraph of Article 42(4) of the same Act.

Therefore, in the case of this case, unless the merger of this case was conducted within five years from the date on which the plaintiffs received the donation of this case from C, but D does not correspond to the case where D was listed by the merger, it cannot be deemed that the ground for increase in property value under Article 42 (4) of the former Inheritance and Gift Tax Act has occurred. Thus, the prior disposition of this case is unlawful on

The instant disposition was revoked, based on the judgment of the court, and each of the instant dispositions was revoked. The Defendants should be seen as the language and text of Article 42(4) of the former Inheritance and Gift Tax Act, and there is no room to regard the “merger by merger” as the “listing by merger,” and in light of the fact that the said provision was newly established as the comprehensive example provision following the introduction of the so-called “Gift Full Malicitism of Gift Tax.”