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. The reasoning of the judgment of the court of first instance as to this case is to be cited or deleted as follows, and except for those cases where the plaintiffs specifically emphasized or additionally claimed as the grounds for appeal, the reasoning of the judgment of the court of first instance is to be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

Part 12 of the 7th decision of the court of first instance to "the subject matter" in the 8th decision of the court of first instance shall be made as follows.

Where the profits of a corporation are distributed to a specially related person due to the high-priced acquisition of new shares when the capital increase in the method of allocating a third party, the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 12, 2016; Presidential Decree No. 26981,

Article 88 (1) 8-2 can be applied to the above provision, and where a corporation's profit is distributed through transactions such as capital increase, capital reduction, merger (including division and merger), division (including division and merger), and conversion, acquisition, and exchange of shares by convertible bonds, etc. under Article 40 (1) of the Inheritance Tax and Gift Tax Act in cases other than subparagraph 8, "if it is deemed that the profit of the corporation was distributed through transactions such as the increase or decrease of the corporation's capital (including the amount of investment) by the convertible bonds, etc. under Article 40 (1) of the Inheritance Tax and Gift Tax Act" shall be defined as "in the first instance judgment of the court of first instance No. 14-15" and "as in this case," the interpretation of the tax law under the principle of strict interpretation derived from the principle of tax law should be interpreted as

The 11th sentence of the first instance judgment and the 13th sentence of the 11st sentence shall be deleted, and "the 2th sentence" shall be added.

2. Additional determination

A. A donation between shareholders due to high-priced subscription of 1 shares alleged by the Plaintiffs is an interest under the Corporate Tax Act.