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).

1. Article 31(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11609, Jan. 1, 2013; hereinafter “Gift”) provides that donated property subject to gift tax shall include all things having economic value that can be converted into money and all de facto or de facto rights having property value.

In addition, Article 60(1) declares the principle of market value by requiring the value of the property on which a gift tax is levied to be in accordance with the market price as of the date of donation. Paragraph (2) of the same Article provides that the market price is “the value generally recognized as being constituted if a transaction is made freely between many and unspecified persons,” and Paragraph (3) of the same Article provides that “where it is difficult to calculate the market price in applying paragraph (1), the value assessed by the methods prescribed in Articles 61 through 65, considering the type

Therefore, property belonging to the donee and having property value which can be converted into money is included in the donated property, and the calculation of the value shall be based on the market price as of the date of donation. However, if the pertinent donated property is not freely traded among many and unspecified persons, and there is no provision in assessing its value immediately and it is impossible to calculate its market price as soon as possible, it shall be taxed on the basis of the amount most appropriate

2. The lower court determined to the following purport by citing the reasoning of the first instance judgment and modifying part thereof.

C On September 25, 2012, Samsung Life Insurance Co., Ltd., policyholders, insured, pension beneficiaries and others.