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. Basic facts

A. Since around 2004, Plaintiff A delegated the tax agency business of his company to the Defendant, who is a certified tax accountant. D is an employee of the tax office operated by the Defendant.

B. On April 5, 2010, Plaintiff A entered into a contract with Plaintiff B, who is an ASEAN, with the burden of acquiring KRW 53 million and the lease deposit obligation amounting to KRW 110 million with respect to the remainder-mortgage 7 Dong 1505 (hereinafter “instant real estate”). On April 6, 2010, Plaintiff B completed the registration of transfer of ownership on the ground of the instant donation.

C. At the time of the instant donation, D prepared and submitted a tax return under the Plaintiffs’ name on the instant donation upon the Plaintiff’s request. However, even though the tax base of the instant real estate was reported higher than the standard market price, D reported only KRW 25 million, which is the standard market price, and on June 30, 2010, Plaintiff A paid KRW 2,210,270,000, and Plaintiff B paid KRW 1,080,000,000, respectively.

On May 18, 2015, the tax authority imposed additional tax of KRW 5,232,927 on May 18, 2015, on the ground that the Plaintiffs underreporting the gift tax and the transfer income tax on the instant donation; KRW 5,959,99,90 in total; KRW 185,246 in total; KRW 7,450,740 in additional amount; KRW 1,420,870,740 in total; and KRW 8,740 in additional amount.

【Ground of recognition】 The fact that there has been no dispute, entry of Gap's evidence No. 12-20, the purport of whole pleading

2. The plaintiffs asserted that they delegated the duty return of the gift of this case to the defendant, who is a tax accountant. The defendant is a tax specialist.