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 reasons why the court of this case cited in the judgment of the court of first instance are as follows, except for the addition of the judgment of the plaintiffs as to the new argument in the trial of the court of first instance under Paragraph 2 below, and therefore, it is consistent with the reasons for the judgment of the court of first instance under Article 8(2) of the Administrative Litigation Act and the main sentence of Article

(2) On January 2, 200, the Plaintiffs asserted that, as related parties under Article 19(2)2 of the former Enforcement Decree of the Inheritance and Gift Tax Act, the term “employee” means a person who actually entered into an employment contract relationship with the pertinent company and received compensation for the provision of labor, and merely entered into an employment contract with the pertinent company and did not have any actual performance of the business, and the Plaintiffs cannot be deemed to be included in the above employees, and thus, the title trust of this case constitutes an exception to the evaluation of evidence that the title trust of this case constitutes “where a person, other than the largest shareholder, etc., receives stocks, etc. in possession of the largest shareholder, etc. within the period prescribed by Article 47(2) of the former Enforcement Decree of the Inheritance and Gift Tax Act and does not constitute an exception to the evaluation of evidence, and therefore, the shares of this case cannot be deemed to be the largest shareholder.

On the other hand, “employee” under Articles 53(3) and 19(2)2 of the former Enforcement Decree of the Inheritance and Gift Tax Act includes “employee” as the same concept as “employee” under Article 13(6)2 of the same Enforcement Decree and includes “employee of a corporation controlled by investment.” Article 4 of the former Enforcement Rule of the Inheritance and Gift Tax Act (amended by Ordinance of the Ministry of Strategy and Finance No. 425 of March 19, 2005) includes employee of a corporation whose largest shareholder, etc. invests more than 30%.