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 why the court should explain this part of the disposition and the relevant law are as stated in each corresponding part of the judgment of the court of first instance. Thus, this part is cited by Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. The Plaintiffs’ assertion 1) In the event that a transaction subject to capital gains tax is a value exchange, the actual transaction price should be calculated based on the value of the benefits actually acquired at the time of individual transfer. On September 16, 201, which is the date of termination of the instant stock transaction agreement, the actual transaction price should not be calculated based on the value of the benefits actually acquired at the time of individual transfer. On September 16, 201, only 7.69 U.S. dollars per share (hereinafter “U.S.”) that the Plaintiffs received at the time

(2) The Plaintiff’s share price at issue is calculated as USD 0.35 per share, which is the stock price on December 16, 2012, and it is unclear whether or not the Plaintiffs have acquired. Since the Plaintiffs actually acquired the common share issued on December 16, 2012, the actual transaction price should be calculated as USD 0.35 per share, which is the stock price on December 16, 2012. 2) Even if the stock price at issue should be calculated as USD 7.69 per share, which is the stock price on the closing date of the transaction, the Plaintiffs were to receive the common share of the LS, which is USD 0.35 per December 16, 2012, and did not request the settlement to the NS Korea, and thus, the transfer price of the instant share was modified according to the actual acquisition price of the Plaintiffs’ common share.

3. Meanwhile, the Plaintiff A asked the Commissioner of the National Tax Service on the scope of the transfer value of stocks based on the instant factual basis prior to filing a return and payment of the transfer income tax on the instant stocks, and the Commissioner of the National Tax Service made a payment to increase or decrease after the transfer