1. All appeals filed by the plaintiffs are dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

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

The reasoning of the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for the modification or addition of a part of the judgment of the court of first instance as follows. Thus, it is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

The parts tending or adding shall be replaced by the following from 11,12 lines “the Income Tax Act” to 14,15 lines “unfortunate” of 3 pages 11,12 lines:

【Plaintiffs cannot be deemed to have a domicile in Korea under Article 1-2 of the Income Tax Act after March 29, 201, pursuant to Article 2(1) of the Enforcement Decree of the Income Tax Act, pursuant to Article 2(1) of the Enforcement Decree of the Income Tax Act, since they moved to Canada, they cannot be deemed to have a domicile in Korea “when determining whether they have a family living together in Korea and a property located in Korea, based on objective facts in their living relationship, such as whether they have a property located in Korea,” and those who have obtained a permanent residence in Korea under foreign laws and regulations pursuant to Article 2(4)2 of the Enforcement Decree of the Income Tax Act, who have resided abroad and obtained a right of residence in Korea, are deemed to have no domicile in Korea, and therefore, they are deemed to have no address in Korea and are deemed to have changed from

In accordance with Article 2(1) of the Enforcement Decree of the Income Tax Act at the time of May 27, 201, the date when deemed the fictitious dividend income accrued, the Plaintiffs are deemed to have a domicile in the Republic of Korea under Article 1-2 of the Income Tax Act in accordance with the objective facts of living relationship, such as the existence of a family living together in the Republic of Korea and of assets located in the Republic of Korea. It is reasonable to deem that the Plaintiffs were to have a domicile in the Republic of Korea. The Plaintiffs constitute a person who has resided in a foreign country under Article 2(4)2 of the Enforcement Decree of the Income Tax Act and has obtained a permanent residence in such foreign country