1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning for the court’s explanation of this case is as follows, except for the addition of the judgment on the plaintiff’s assertion in the court of first instance to the following, thereby citing this case’s assertion by Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. The plaintiff's assertion

A. According to the text of the statement prepared at the time of investigation by the National Tax Service, the Plaintiff only stated the circumstances related to the third acquisition, and did not allow the first acquisition and the second acquisition. The testimony of the Plaintiff for the first acquisition is not trustable. The delivery of the seal imprint certificate and the certificate of seal imprint to the non-party company (B corporation) is merely the practice of the company for business convenience. In the case of the capital increase in documents in 2006, the Plaintiff did not know the fact that the Plaintiff was issued with the capital increase. In the case of the third acquisition, there is no title trust agreement related to the first and second acquisition. (2) In the case of the third acquisition, there is no title trust agreement related to the third acquisition, which would put C to disadvantage, such as dismissal, and even if the name transfer was made, it was made by deceiving it as if there is no disadvantage. Accordingly, the Plaintiff revoked the title trust agreement related to the third acquisition with the declaration of intent by fraud or coercion. Accordingly, the title trust agreement retroactively becomes null and void

3) The Plaintiff’s acquisition of shares under a false transfer contract constitutes a false declaration of intention and a false declaration of intention and a false declaration of intent. (B) Although it is apparent that the financial statements of the Nonparty Company are false data prepared by the window dressing accounting, the Defendant’s disposition imposing gift tax is unlawful.

2. When considering the real value of the real estate held by C at the time of 2010, the items of provisional payments to C shall correspond to the claims that are impossible to be recovered as of the date of donation, and the value of the shares of this case shall be appraised in accordance with the supplementary assessment methods.