1. The plaintiffs' appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning of the court’s explanation concerning this case is as stated in the reasoning of the judgment of the court of first instance, except for addition or modification of the same content as that of the judgment of the court of first instance. Thus, this is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Details to be used or deleted in the part of reasons for the judgment in the first instance;

A. Article 179(10)2 of the Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 179(10)2 of the Income Tax Act) of the 6th 12 of the 6th 12 of the 6th 12 of the 5th 12 portion of the reasoning of the judgment of the first instance.

B. Of the items 2.C. of the reasoning of the judgment of the first instance court, the following is added to the items “(2) the basis and limit of the delegated legislation.” Meanwhile, at the trial of the first instance, the Plaintiffs added the assertion that the enforcement Decree of this case is null and void as it violates the principle of equality. In light of the legislative purpose of the Income Tax Act on non-residents under the Income Tax Act, such as where the taxation authority of various taxation countries overlap or it may not extend to the taxation authority of any taxation country, and thus, it is necessary to treat differently with residents in the transfer income tax or other similar income in taxation under the Income Tax Act, and thus, there is a reasonable reason to treat differently with residents and non-residents. Therefore, the above argument by the Plaintiffs is without merit. (c) On the other hand, the part of the reasoning of the judgment of the first instance court, which is to be deleted, is deleted.

Article 2(c) of the reasoning of the judgment of the first instance court is added to Paragraph (4) at the end of the second instance judgment as follows. 4) The Plaintiffs are obligated to pay additional tax, and the former Income Tax Act and the Enforcement Decree stipulate the conflicting contents, and the Plaintiffs, who are non-professionals in tax law, are subject to taxation on the transfer of stocks of this case.