1. The plaintiffs' appeal is 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. Basic facts

A. Plaintiff A is children between the network C and D, Plaintiff B is the wife of Plaintiff A, and Party E is the incidental between the network C and I, and Party F is the son between the network C and G.

B. In around 2011, Plaintiff A and Plaintiff B owned 7,027 shares of the total 15,444 shares of H Co., Ltd. (hereinafter “H”), respectively.

C. E owns 900 shares out of the shares of J Co., Ltd. and 2,342 shares out of the shares of the said Co., Ltd., and E and F respectively donated all of the shares owned by H around January 4, 201.

(2) Each of the instant donations was made. Meanwhile, H had carried forward losses of KRW 7,896,064,484 at the time each of the instant donations was made.

Article 41(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance and Gift Tax Act”) (hereinafter “instant provision”), Article 41(1) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Act No. 1817, Dec. 30, 2003; hereinafter “former Inheritance and Gift Tax Act”), Article 31(6) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 18195, Feb. 21, 2014; hereinafter “the former Inheritance and Gift Tax Act”) (hereinafter “the former Inheritance and Gift Tax Act”); and Article 41(1) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 25195, Dec. 30, 2003; hereinafter “the former Enforcement Decree of the Inheritance and Gift Tax Act”).

(hereinafter referred to as “each gift tax of this case”) paid by the Plaintiffs.

On November 30, 2012, the Daejeon District Court rendered a decision that the gift tax base and calculated tax amount on each gift of this case are the same as the amount paid by the plaintiffs on February 29, 2012.