1. The plaintiffs' claims against the defendants are all dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. The E Co., Ltd. (hereinafter “E”) is a company that runs a general book and textbook publishing business on January 15, 1990.

B. On November 15, 2004, F, who served as the representative director of the non-party company, transferred 60,000 shares of the non-party company owned by himself (hereinafter “instant shares”) to the officers and employees of the non-party company including the plaintiffs, and completed the transfer of title.

C. The Defendants: (a) applied Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”) on the grounds that the Plaintiffs received title trust from G, the actual owner of the non-party company’s shares; (b) determined and notified the Plaintiffs of gift tax, as shown in [Attachment 1].

(hereinafter “instant disposition”) D.

The Plaintiffs were dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 20, 2015, but was dismissed on August 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 11, Eul evidence Nos. 1 and 11 (including additional numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiffs alleged that they were entitled to title trust by H, not individuals G, and since H is exempt from taxation for profit-making businesses in practice as religious organizations, there is no room for recognizing the purpose of tax avoidance.

On the other hand, H made a title trust of the shares to the Plaintiffs, who are the believerss, due to the question whether a religious organization may become a shareholder of the non-party company that conducts profit-making business, concerns that the non-party company or its officers and employees may suffer disadvantages if the non-party company becomes a corporation operated by H, and that the non-party company is a corporation operated by H in the same manner.

B. The details of the relevant statutes are as shown in Appendix 2 of the relevant statutes.

(c) 1 key issue;