1.The judgment of the first instance shall be modified as follows:

On December 2, 2015, the defendant belongs to the net A in 2010.

1. The reasoning of the judgment of the court of first instance is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, except for the grounds of the judgment of the court of first instance, for the following reasons:

2 Myeon 11 shares "41,358 shares" shall be deemed "41,538 shares".

In addition, "2,308,821,658" is "2,308,821,657" as "2,308,821,657"; "461,764,332" as "461,764,331"; "63,078,89" as "63,078,898"; "3,403,664,888" as "3,664,886" in the aggregate column as "3,403,664,886 (However, less than ten won was reduced and imposed by 3,403,664,880 won)" as "6.

4. The number of pages 2 of the table " January 10, 2016" shall be " November 10, 2016."

4. Parts 7 to 6, 14 of the 4th page table are as follows:

A. As to the Plaintiffs’ assertion on the unconstitutionality of the provisions of the Addenda to the Restriction of Special Taxation Act, Article 38-2(3) of the former Restriction of Special Taxation Act provides that “If any of the following causes occurs, a shareholder who has been subject to the deferred taxation of capital gains tax or corporate tax pursuant to paragraph (1) or (2) shall pay capital gains tax or corporate tax that has been subject to the deferred taxation, as prescribed by Presidential Decree.” However, the Special Taxation Act amended by Act No. 10406, Dec. 27, 2010 (amended by Act No. 10406, Nov. 1, 2011).

Article 38-2 (3) shall be the book value of the stocks acquired by investment in kind or treasury stock exchange if the stockholders of a domestic corporation have been subject to deferred taxation under paragraph (1) or (2), and the holding company shall be the book value of the stocks acquired by the investment in kind or treasury stock exchange, and any of the following causes shall occur during