All appeals are dismissed.

The costs of appeal by Plaintiff A are assessed against Plaintiff A and Defendants.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Determination on the grounds of appeal regarding the donation of August 10, 2007

A. As to the Plaintiff A’s grounds of appeal Nos. 1, 2, and 3, the lower court, on the grounds indicated in its reasoning, determined that the tax investigation conducted in violation of Article 81-4(2) of the former Framework Act on National Taxes (amended by Act No. 12162, Jan. 1, 2014; hereinafter the same shall apply in this paragraph) on the gift of stocks of M& Co., Ltd. (hereinafter “M”) on August 10, 2007 cannot be deemed an illegal reinvestigation.

In light of the relevant legal principles and records, the lower court’s reasoning was partially inappropriate, but its conclusion that the said tax investigation constituted a tax investigation permissible under the former Framework Act on National Taxes is justifiable. In so doing, contrary to what is alleged in the grounds of appeal, there were no errors by misapprehending the legal doctrine on the interpretation of exceptional reasons

B. As to Plaintiff A’s ground of appeal No. 4, 1) citing the reasoning of the judgment of the first instance, the lower court acknowledged the following reasons as follows: (i) donated L to Plaintiff A, who is an son on August 10, 2007, 758,980 shares of M, which were held in the name of each O on August 10, 207; (ii) the Plaintiff reported to the head of Yongsan Tax Office on March 17, 2008 after the deadline for gift tax including penalty tax, with the donor as the networkO; and (iii) the head of Gangnam-gu Tax Office reported the gift tax amount, including penalty tax, and paid in kind M shares; and (iv) the Defendant Gangnam-gu Tax Office notified the Plaintiff of the increase in the principal tax and the penalty tax on the total amount of the principal tax increased due to the increase in donation price and the re-donation of stocks on January 11, 2013; and (v) notified that penalty tax should be imposed on June 19, 2014.