1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance is the same as the reasoning of the judgment of the court of first instance, except for the dismissal or addition of the following contents among the grounds of the judgment of the court of first instance. Therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

① Then, “If the Plaintiff had actively intended the result of tax avoidance arising from the title trust of this case, it would be consistent with the fact that the title trust of this case was made with a purpose different from the tax avoidance of the C’s corporate investment (D-8) status acquisition, and thus, it would be consistent with the fact that the title trust of this case was made with C, as the Plaintiff had actively intended the result of the tax avoidance arising from the title trust of this case, the lower limit was higher than the lower limit.”

② On the 7th page 13, the phrase “only KRW 14.9 million” is considered as follows: “The Plaintiff is KRW 20 million (the Plaintiff is KRW 20,180,000; the Defendant asserts KRW 20,705,000).”

2. Thus, the plaintiff's claim is justified, and the judgment of the court of first instance is just, and the defendant's appeal is dismissed as it is without merit. It is so decided as per Disposition.