All appeals are dismissed.

The costs of appeal are assessed against the Defendants.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Regarding ground of appeal No. 1

A. The main text of Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”) provides that “where the actual owner and the nominal owner are different with respect to property (excluding land and buildings; hereinafter in this Article the same shall apply), the value of the property shall be deemed to have been donated to the actual owner on the date when the actual owner are registered as the nominal owner (where the property requires a change of ownership, referring to the day following the end of the year following the year in which the date of acquisition of ownership falls), notwithstanding Article 14 of the Framework Act on National Taxes, the value of the property shall be deemed to have been donated to the actual owner (hereinafter referred to as “instant provision”), and Article 45-2(2) of the same Act provides that “Where the property, etc. is registered in another person’s name, and the title holder fails to file a report on the change of ownership or transfer income tax under Article 105 of the Income Tax Act.”

In light of the language and structure of the instant provision and the provision on deemed donation by transfer of entry, in cases where a person who acquired stocks fails to transfer to a third party for a long time, the primary taxpayer of gift tax is the trustee when such provision is applied.