All appeals by the plaintiffs are dismissed.

The costs of appeal are assessed against the plaintiffs.

The purport of the claim and appeal is the purport of the appeal.

1. The grounds for appeal by the plaintiffs citing the judgment of the court of first instance are not significantly different from the allegations in the court of first instance, and the judgment of the court of first instance is justified even if all the evidences presented in the plaintiffs' arguments and the court of first instance

Therefore, this court's reasoning is identical to the reasoning of the judgment of the first instance except for dismissal or addition as follows. Thus, this court's reasoning is acceptable in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. On the 5th page of the judgment of the court of first instance, the following shall be added to “each person who is the second taxpayer of each F. .............”

The plaintiffs asserted to the effect that "On the other hand, the imposition of secondary tax liability is improper merely because they held part of the company's shares."

However, as seen earlier, Article 39 subparag. 2 of the former Framework Act on National Taxes, Articles 20(2) and 18-2 subparag. 1 of the Enforcement Decree of the Framework Act on National Taxes provide that the secondary tax liability shall be borne for the oligopolistic shareholder. In the case of oligopolistic shareholder, there is no provision or other legislation that excludes the oligopolistic shareholder from the subject of the secondary tax liability, and thus, the aforementioned Plaintiffs’ assertion cannot be accepted.

[Attachment 13 to 16] Part 5 of the first instance judgment is as follows.

According to relevant regulations and legal principles, Article 12(1)1 of the Gross Real Estate Tax Act, and the main text of Article 107(1) of the Local Tax Act, “a person who actually owns property” as of June 1 of each year, which is the property tax assessment basis date, is liable to pay the comprehensive real estate holding tax.

The term "person who actually owns the property" refers to a person who actually owns the property regardless of whether it is registered as the owner on the public register.

(See Supreme Court Decision 2002Du6361 Decided November 28, 2003, etc.)

3. Conclusion.