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1. The plaintiffs' claims against the defendants are all dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
Reasons
1. Details of the disposition;
A. The representative director of D Co., Ltd. (unlisted corporation, incorporated into E on April 29, 2002, a mutual change to D Co., Ltd. on December 1, 2005, hereinafter “D”) acquired 325,000 shares of D on January 10, 206 (hereinafter “instant one shares”) at KRW 325,00,000 (hereinafter “instant 5,000 won per share”). From January 16, 2006 to March 6, 2006, G Co., Ltd. (Establishment into H Co., Ltd. on July 19, 199; Change to G Co., Ltd. on July 29, 2005; hereinafter “D”) to G Co., Ltd. on July 6, 2007; and delisted the issues of each of the said shares to G Co., Ltd. on the aggregate of KRW 300,300,93.19.27.
B. On December 13, 2005, Plaintiff B and C participated in the allocation of new shares to a third party by J (unlisted corporation, establishment on November 6, 1998, hereinafter “J”) and acquired 4,545 J shares in KRW 49,950,000 (hereinafter “instant 2 shares”), respectively (hereinafter “instant 2 shares”), and transferred 639,480,000 shares in March 27, 2006 to G (140,700 won per share), and acquired 227,573 shares in the allocation of new shares (hereinafter “occupant 3 shares”) to a third party on March 28, 2006, and acquired 639,480,000 shares in each of them.
C. On October 19, 2009, the Daejeon Regional Tax Office investigated the issues related to the general consolidated investigation of G’s corporate tax, D, and J, and confirmed that Plaintiff A was the actual owner of each of the issues, and held title trust thereof. The competent tax authority notifies Plaintiff A of the imposition of gift tax following the high-value transfer under Article 35 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “the Inheritance Tax Act”) on the transfer of one of the issues at issue, and the imposition of gift tax following the increase in capital under Article 39 of the former Inheritance Tax and Gift Tax Act on the acquisition of new shares at issue at issue at issue, and the imposition of gift tax on Plaintiff B and C based on the constructive gift of title trust under Article 45-2 of the latter Inheritance Tax and Gift Tax Act on three shares.