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 for the court’s explanation concerning this case are as follows, and the plaintiffs’ assertion, which is particularly emphasized in the trial, are as stated in the reasoning of the judgment of the court of first instance, except for the addition of the judgment, such as the following Paragraph 2, and therefore, they are cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The fourth reduction of the 12th judgment of the first instance court shall be referred to as "Plaintiff K" as "Plaintiff B B."

Of the attached Form 14 of the judgment of the first instance court, the "Act on Real Name Financial Transactions and Confidentiality" in the attached Form 14hh among the "related Acts and subordinate statutes" is deemed to be "the former Act on Real Name Financial Transactions and Confidentiality (Amended by Act No. 12711, May 28, 2014)", and the "Enforcement Rule of the Act on Real Name Financial Transactions and Confidentiality" in the first sentence of the 15th sentence is deemed to be "the former Enforcement Rule of the Act on Real Name Financial Transactions and Confidentiality (Amended by Ordinance of the Prime Minister No. 1110, Dec. 5, 2014)" respectively.

2. Additional determination

A. The defendant's disposition of this case was based on KRW 3,006,047,793 of the value of the shares of this case. The above value includes shares that the plaintiff Eul transferred to a securities account in the name of the plaintiff A and acquired as a loan of KRW 1,391,809,235 of the loan granted as security. Thus, the remaining amount of KRW 1,614,238,558 of the loan should be imposed after deducting the above loan.

Therefore, the defendant's disposition of this case, which is based on different premise, is against the economic substance or against the principle of double taxation prohibition.

B. The provision on deemed donation under Article 45-2(1) of the Inheritance Tax and Gift Tax Act is an independent property that requires the transfer or exercise of the right, and where it differs from the actual owner and the nominal owner, the fact of such formal act is taxable.

It is a provision that imposes gift tax on a case, and is donated pursuant to the above provision.