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.

1. The reasons for the entry of this case by the court of first instance concerning this case are as follows: (a) the "E" of the last two deeds of the judgment of the court of first instance is dismissed as "E"; (b) the fourth 18-21 of the judgment is deleted; and (c) the plaintiffs are the same as the entry of the reasons for the judgment of the court of first instance in addition to adding the judgment of the court of first instance as to the allegations that the plaintiffs have repeated in the trial, and thus, they are cited as it is in accordance with Article 8(2) of the Administrative Litigation Act;

(hereinafter the meaning of the abbreviationd language used in this context is the same as the judgment of the first instance). 2. Additional decision

A. The Plaintiffs’ assertion falls under Article 41 of the former Inheritance and Gift Tax Act (Donation of profits through transactions with specific corporations).

Even if the gift tax is not imposed pursuant to Article 2 (2) of the former Inheritance and Gift Tax Act, it shall be deemed excluded from the gift tax.

B. In full view of the following facts, so long as the gift of this case falls under Article 41 of the former Inheritance and Gift Tax Act, it cannot be deemed that the gift of this case is excluded from taxation subject to gift tax pursuant to Article 2 (2) of the former Inheritance and Gift Tax Act. Thus, the plaintiffs' assertion is without merit.

1) The main sentence of Article 2(2) of the former Inheritance and Gift Tax Act provides that “No gift tax shall be imposed where a donee imposes income tax under the Income Tax Act and corporate tax under the Corporate Tax Act on donated property under paragraph (1) before being amended by Act No. 11130, Dec. 31, 2011.” However, in light of the language and text and content thereof and the nature of the gift tax as a supplementary tax, the former provision has been interpreted as “where gift tax is imposed on a donee, no gift tax shall be imposed” (see, e.g., Supreme Court Decision 2013Du1524, Oct. 29, 201) and the Inheritance and Gift Tax Act (see, e.g., Supreme Court Decision 2013Du1524, Oct. 29, 2015) with respect to transactions with the so-called “special relationship for sunset cycle” under Article 45-3 as of December 31, 2011.