1. The judgment of the court of first instance is modified as follows.

See Attached Table 1, each of which the Defendants committed against the Plaintiffs.

1. The reasoning for the judgment by the court on this part is as stated in the corresponding part of the judgment of the court of first instance, in addition to the following parts, the reason for the judgment is as stated in this part. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

Part 3 to 4 (hereinafter referred to as "3 to 4") shall be deleted from the second bottom of the judgment of the first instance.

At the second bottom of the judgment of the court of first instance, “On the other hand, Plaintiff A’s children are Plaintiff B’s children, Plaintiff D is Plaintiff E’s wife, and Plaintiff C is Plaintiff E’s father.”

For the 3-party 8 transaction in the first instance judgment, the following "(hereinafter referred to as "each transaction in this case") shall be added."

2. Whether the disposition is lawful;

A. Each of the instant transactions asserted by the Plaintiffs does not constitute acquisition of property at a price lower than the market price, since there is no reason to believe that there is transaction example corresponding to the market price and that there is improper reason.

In addition, each of the instant transactions was conducted for the recovery of investment money in the course of liquidation of a business relationship, and there is no motive to distribute profits to each of the instant transactions, and the acquisition price of each of the instant transactions is determined by taking into account the management status of the instant company at the time of transfer and anticipated future performance, etc. As such, there is a justifiable reason in terms of the transaction practice in each of the instant transactions (other than No. 5 of attached Table 3).

Nevertheless, under the premise that the value calculated by supplementary evaluation methods under the former Inheritance and Gift Tax Act is the market value of the shares of the instant company, each of the instant dispositions imposing gift tax by deeming that the Plaintiffs acquired property from a related party at a lower price, or acquired property from a person who is not a related party at a significantly lower price than the market price without justifiable grounds under transaction practices

(b) Attached Form 4 of the relevant statutes;

C. Relevant legal principles 1.