All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

Article 14(1)4 of the former Restriction of Special Taxation Act (amended by Act No. 921, Jan. 1, 2010) provides for the special taxation that excludes income accruing from the transfer of stocks or equity shares acquired by investing in a venture business from the taxation subject to capital gains tax. Article 12(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 22037, Feb. 18, 2010) provides that “stocks or equity shares prescribed by Presidential Decree under Article 14(1)4 of the Act shall mean stocks or equity shares acquired by an investment in conformity with the provisions of subparagraphs 1 and 2 and five years have passed from the date of such investment in a venture business (referring to a venture business under Article 2(1) of the Act on Special Measures for the Promotion of Venture Businesses) or a venture business which is converted into a venture business within three years from the date of its establishment.”

After compiling evidence, the lower court acknowledged the facts as indicated in its reasoning, and comprehensively based on the text, structure, legislative intent, and history of amendment, etc. of the relevant provisions, the term “investment in venture businesses within three years after establishment” under Article 12(1)1 of the former Enforcement Decree of the Restriction of Special Taxation Act means “investment in venture businesses within three years after establishment of a venture business” and “investment in venture businesses within three years after establishment of a venture business” under Article 12(1)1 of the former Enforcement Decree of the Restriction of Special Taxation Act. Since shares acquired by the Plaintiffs at the time of establishment of a venture business after establishment of a new venture business, such as E, constitute shares acquired by “investment in venture businesses within three years after establishment of a new venture