All appeals are dismissed.

The costs of appeal by the plaintiffs are assessed against the plaintiffs and the defendant.

The grounds of appeal are examined.

1. As to the Defendant’s ground of appeal

A. Article 107(1) of the Local Tax Act provides that “A person who actually owns property” that is liable to pay property tax pursuant to Article 107(1) means a person who owns a real ownership of the relevant land or property, regardless of whether a title truster is registered as an owner on the public register (see, e.g., Supreme Court Decision 2010Du4964, Dec. 13, 2012). In cases of a three-party registered title trust between a title truster and a title trustee who directly executes a title trust agreement with the title trustee and conducts an ownership transfer of the relevant real estate under the name of the title trustee, the title truster’s status as a purchaser is not different from that of the general sales contract (see, e.g., Supreme Court en banc Decision 2014Du4310, Mar. 22, 2018). If the title truster concluded a sales contract on real estate and paid all the purchase amount, barring any special circumstance, the title truster is liable to pay property tax imposed on the title trustee or the title trustee’s.