1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. C Co., Ltd. (hereinafter “instant company”) whose representative director is C is a corporation operating the electrical construction business, etc., and Plaintiff A (former E prior to the name of the Plaintiff”) who is C is an outside director, and Plaintiff B, who is a kyman, is currently in office as an agent of the said company.

B. C: (a) on March 31, 201, transferred 12,600 shares out of the total 42,000 shares of the instant company (hereinafter “instant shares”) owned by it to the Plaintiff A; and (b) on October 15, 201, the Plaintiff transferred the said shares to the Plaintiff B, the Plaintiff filed a preliminary return of transfer income tax with the Defendant on October 15, 2012.

Meanwhile, in the business year 201 and 2012, C transferred the instant shares to the Plaintiff in 2011, and the Plaintiff A again transferred them to the Plaintiff in 2012. The detailed statement on the state of the fluctuation of Stocks, etc. in the business year 2012 (hereinafter “detailed statement on the state of the fluctuation of Stocks, etc. in this case”).

C. On March 6, 2015, under Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter the same), the Defendant deemed that C, an actual owner of the instant shares, held a title trust with the Plaintiffs, imposed gift tax of KRW 106,072,480 on the Plaintiff A, and on April 1, 2015, KRW 205,253,60, respectively, on the Plaintiff B, respectively.

(hereinafter referred to as "disposition in this case"). 【No dispute exists, Gap evidence Nos. 1, 2, Eul evidence Nos. 1 and 2 (including each number; hereinafter the same shall apply), and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The instant disposition of the Plaintiffs’ assertion is unlawful for the following reasons, and thus should be revoked.

1. Article 45-2(3) of the former Inheritance Tax and Gift Tax Act is not applicable on the ground that C, the owner of the instant shares, prepared the shareholder registry in 2009, did not change the Plaintiffs into the shareholder registry of the instant shares, and thus, the Plaintiffs’ consent.