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 reasoning of the lower court’s explanation concerning this case is as follows: (a) except for the addition of the fourth part from the sixth part of the first instance judgment to the part following the fourth part of the judgment, the corresponding part of the reasoning of the first instance judgment is identical to that of the second instance judgment; and (b) thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

8. The Plaintiffs: Article 157(4) of the former Enforcement Decree of the Income Tax Act (hereinafter “instant provision”).

If the concept of major shareholder is applied to non-small and medium-sized enterprises, the non-major small and medium-sized enterprises are at a disadvantage compared to those listed on the KOSDAQ market, and it is against the tax equity, and it also claims that Article 104 (1) 11 (b) of the former Income Tax Act stipulating preferential tax rates for small and medium-sized enterprises is unfair.

However, in order to promote the initial stock market, the system has been amended in the direction of imposing capital gains tax on the stocks of an unlisted corporation other than a listed corporation and imposing capital gains tax on the transfer of stocks of a listed corporation. In particular, in cases where the activation of the stock market is contrary to the activation of the stock market, the company is subject to taxation on listed stocks transferred by a major shareholder and listed stocks transferred outside the securities market, i.e., (e., stocks transferred by a major shareholder and listed stocks transferred outside the securities market; (b) in cases of an unlisted corporation, regardless of whether a major shareholder or a minority shareholder is a major shareholder or a minority shareholder, it is difficult to readily conclude that a listed company is disadvantaged by an unlisted small and medium enterprise without due consideration to other circumstances, even if the major shareholder standard is equally applied to the listed corporation and the unlisted corporation, such problem is different from that of the listed company.