1.The judgment of the first instance shall be modified as follows:

The director of the Gangnam-gu Tax Office's tax office on January 2, 2012 is limited to the plaintiff A.

1. Details of the disposition;

A. D Co., Ltd. (hereinafter “F”) established on February 22, 1988, changed its trade name to “E Co., Ltd.” on January 4, 1993, and F Co., Ltd. (hereinafter “F”) changed its trade name on April 1, 2006 to P Co., Ltd.

On May 27, 2000, the trade name was acquired in G Co., Ltd. and changed to H Co., Ltd. on April 1, 2006.

B. On March 31, 2005, “I, J, K, L, M, N, andO” (hereinafter “transferor”) transferred the instant company’s shares (hereinafter “instant shares”) to the Plaintiffs at 10 won per share.

The transferee of the transferor’s shares (States) I paid for the shares A. 515,491 5,154,910 J 412,393 4,123,930 K 613,613,623 6,136,230 L 412,393 4,123,930 M 108,066 108,0660, B 871,367 8,713,670 N 128,8731,288,730O 546,235,462,350 Plaintiffs C1,953,9019,539,539,000

C. According to Article 63 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 7580, Jul. 13, 2005; hereinafter “the Act”), the Defendants assessed the value of the instant shares as KRW 2,898 per share (3,767 per share, adding 30/100 to Plaintiff A and B), and determined that the Plaintiffs acquired the instant shares from the transferor at a price considerably lower than the market price without justifiable grounds in light of transaction practices, the Defendants imposed gift tax of KRW 4,243,69,420 on Plaintiff A, and gift tax of KRW 3,378,90,610 on Plaintiff B as shown in the separate sheet No. 1, Jan. 2, 2012, the Defendants imposed gift tax of KRW 4,243,69,420 on Plaintiff C, as indicated in the separate sheet No. 1, Dec. 1, 2012.

(hereinafter “instant disposition”) D.

The Plaintiffs appealed and filed a petition with the Tax Tribunal for a trial on February 28, 2012, but the said petition was dismissed on December 12, 2012.

[Reasons for Recognition] Facts without dispute, Gap evidence 2, 10, 14 through 17 (including each number; hereinafter the same shall apply) and Eul evidence 8 to 11;