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 judgment of the court of first instance cited in this case is as stated in the reasoning of the judgment of the court of first instance, in addition to the parts to be filled or added below, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The 8th two parallels in the judgment of the first instance to the last two parallels (including the main part) shall be followed as follows:

Article 157(4) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26982, Feb. 17, 2016; hereinafter the same shall apply) that was enforced at the time of the instant disposition against the Plaintiffs, based on Article 94(1)3 of the former Income Tax Act, provides for the concept of the major shareholder as follows.

(1) One stockholder or one investor (hereafter referred to as "one stockholder" in this Chapter) holding stocks or investment shares of a corporation (including preemptive rights to new stocks, and securities depository receipts under paragraph (1); hereafter referred to as "stocks, etc." in this Chapter) and a related party under Article 1-2 (1) and (3) 1 of the Enforcement Decree of the Framework Act on National Taxes (hereafter referred to as "other stockholders" in this Chapter) of the Enforcement Decree of the Framework Act on National Taxes as of the end of the business year immediately preceding the business year in which the transfer date of stocks, etc. belongs, means a corporation that has issued 2/10 [the stock certificates listed on the KOSDAQ market (hereinafter referred to as " KOSDAQ market") under Article 8 of the Addenda to the partial amendment to the Enforcement Decree of the Financial Investment Services and Capital Markets Act

· or KONEX-listed corporation (referring to a corporation that has issued stock certificates listed on the KONEX under Article 11(2) of the Enforcement Decree of the Financial Investment Services and Capital Markets Act (hereinafter referred to as the "KONEX");

Stocks, etc. of venture businesses under Article 2 (1) of the Act on Special Measures for the Promotion of Venture Businesses which are traded pursuant to Article 178 (1) of the Enforcement Decree of the Financial Investment Services and Capital Markets Act.