1. All appeals by the Defendants are dismissed.

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

Purport of claim and appeal

1.

1. The reasoning of the court’s explanation as to this case is as follows, except for the addition of the judgment on the additional allegations made by the Defendants in the trial under Paragraph (2) below, the reasoning of the judgment of the court of the first instance is as stated in the part of the reasoning of the judgment. As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation

2. The addition;

A. Even if Plaintiff A, B, and C’s assertion (additional Grounds for Preliminary Disposition) acquired the instant shares without title trust, the said Plaintiffs did not have paid to Plaintiff I or D, and thus, acquired the instant shares free of charge.

Therefore, Plaintiff A, B, and C are obligated to pay gift tax pursuant to Articles 2(3) and 4(1) of the Inheritance Tax and Gift Tax Act, and Plaintiff D is obligated to jointly pay gift tax with the above Plaintiffs, a donee, pursuant to Article 4(4) of the same Act. Thus, each disposition imposing gift tax of this case is lawful.

B. First of all, we examine whether the foregoing preliminary disposition is legitimate, and since the subject matter of the lawsuit is objective existence of legitimate tax amount, the tax authority may submit new data that can support the legitimacy of the tax base or tax amount recognized in the pertinent disposition or exchange and change the reasons to the extent that the identity of the disposition is maintained, even during the lawsuit (see, e.g., Supreme Court Decisions 97Nu2429, Oct. 24, 1997; 2000Du4873, Aug. 24, 2001; 2000Du4873, Aug. 24, 2001). The grounds for the initial disposition of each of the instant preliminary disposition can be added to one objective fact-finding for which the transfer of ownership was made with respect to the shares 1 of this case.

The proposal structure and legal evaluation are different, and it does not change the basic facts that form the basis of taxation.