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 for the court’s explanation of this case is as follows: (a) the reasoning for admitting the judgment of the court of first instance is as stated in the part of the reasoning of the judgment of the court of first instance, except for the dismissal under Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, since the court’s explanation of this case is the same as that of the judgment of the court of first instance.

2. In light of the following circumstances, it is reasonable to deem that the transfer of each of the instant shares constitutes a gift, and accordingly, the Defendant’s imposition of the gift tax and the additional tax is lawful, based on the premise that the transfer of each of the instant shares constitutes a gift.

The evidence No. 10-1, evidence No. 14-1, and evidence No. 14-2, evidence No. 14-1, and evidence No. 14-2, evidence No. 10-1, and evidence No. 14 of the first instance trial witness F and G alone do not obstruct

① Each statement delivered by the Plaintiffs to F contains the following: (a) the Plaintiffs are fair in participating in the management; (b) the Plaintiffs bear the responsibility arising from their own fault; and (c) the transfer of E shares that were acquired from F to F in the event of resignation from E’s director due to personal reason.

However, around March 29, 201, Plaintiff A, B, and C were assigned E’s shares as an internal director of E and were transferred. At the time, Plaintiff D’s internal director was only Plaintiff D with the exception of the above Plaintiffs and F. However, Plaintiff D’s transfer of E shares around November 12, 201, etc. In light of the fact that Plaintiff D received the same degree of E shares as the above Plaintiffs, it is highly probable that each of the instant shares was donated for “management participation” as well as “principal spirit and morale” explained in the process of investigation by Seoul Regional Tax Office on the ground that the Plaintiffs were in the status of E director.

② The Plaintiffs are prohibited from transferring each of the instant shares in their respective notes to another person and from withdrawing from the directors.