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 judgment of this court citing the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except where the judgment of the Defendants’ assertion is added as set forth in paragraph (2) below.

2. Judgment on the defendants' assertion

A. The Defendants asserted that since there is no corporate tax amount in arrears and the second tax payment notice for D is not legitimate, since D’s second tax payment obligation is not in arrears, there is no tax amount of KRW 2,980,570,720, ② there is no loan obligation of KRW 1.1 billion against D’s Defendant B, ③ the disposition of imposition of capital gains tax of KRW 402,332,000 was revoked, and the above tax amount in arrears is not in arrears. ④ Since D paid KRW 80,44,200, global income tax of KRW 80,444,16,200 in 205, the deduction of each of the above amounts would amount to KRW 4,44,16,233, and further received a decision of additional reduction according to the decision of the Tax Tribunal, the small property does not exceed positive property.

However, the evidence Nos. 31 and 32 alone is insufficient to admit the aforementioned claims, and there is no other evidence to prove otherwise. The Defendants’ assertion that even if the amount of claims is deducted, there is no evidence to support the Defendants’ assertion that the small property exceeds the active property as seen earlier, and that the amount of claims is not in excess of the obligation. Thus, the Defendants’ assertion is without merit.

B. The Defendants asserted that the statute of limitations has expired as of October 2, 2014, on the tax imposed on October 1, 2004 to 2008 on the tax amount attributed from 2004 to 2008. However, there is no specific assertion or proof regarding the statute of limitations, and such assertion alone is difficult to deem that the statute of limitations has expired.

The above assertion by the Defendants is without merit.

3. Conclusion, the first instance judgment is justifiable.

All appeals by the defendants are dismissed as without merit. It is so decided as per Disposition.