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 reasoning of the court's explanation concerning this case is as follows: (a) the "month" of Part 7, No. 19, of the first instance court's decision, and the "disposition" of Part 8, No. 18, are used as "tax disposition"; and (b) the reasoning of the judgment of the first instance is the same as that of the part of the first instance court's judgment, except for addition of the judgment on the assertion added by the plaintiff trust company in the first instance as described in the following Paragraph 2. Thus, it is cited as it is in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of

2. Additional judgment;

A. Article 107(1)3 of the amended Act, which provides that property tax on the trust property claimed by the Plaintiff trust company shall be imposed on the trustee, who is the title holder of the formal registration, notwithstanding the fact that the actual owner of the trust property is the truster (hereinafter “instant legal provision”) is unconstitutional, which infringes on the right of equality or infringes on the Plaintiff trust company’s property right by violating the principle of excessive prohibition, contrary to the constitutional principle of substantial taxation. The instant tax disposition is unlawful as it was based on the law that

B. Whether the principle of tax equality and the principle of tax equality violate the principle of tax equality is an expression of tax law on the principle of equality under Article 11(1) of the Constitution, and the State is obliged not only to enact a law so that the burden of tax can be equally allocated among the citizens in tax legislation, but also to equally treat all the citizens in interpreting and applying the tax law. One of the legal systems to realize such principle of tax equality is the principle of substantial taxation as stipulated in Article 14 of the Framework Act on National Taxes. In a case where the principle of substantial taxation is inconsistent with the legal form and the economic substance, it would pursue the economic substance and impose taxes fairly by imposing taxes (see, e.g., Constitutional Court Order 200Hun-Ba40, Jul. 19, 2001).