All appeals are dismissed.

Costs of appeal shall be borne by each party.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Judgment on the Plaintiff’s grounds of appeal

A. As to the ground of appeal No. 2, Article 14(1) of the Framework Act on National Taxes (see, e.g., Article 14(1) of the same Act), in cases where there is another person to whom the property belongs, different from the name of the person to whom the property belongs, depending on type or appearance, the nominal owner of the property is not the person to whom the property belongs, but the person to whom the property belongs is to be the person to whom the property belongs, and there is another person who substantially controls and manages the property through the control, etc. over the nominal owner, and where the disparity between the nominal owner and the real owner arises from the purpose of tax evasion, the income from the property shall be deemed to

(see, e.g., Supreme Court en banc Decision 2008Du8499, Jan. 19, 2012). This principle applies to the interpretation and application of a tax treaty having the same effect as an Act, barring any special provision excluding such interpretation and application (see, e.g., Supreme Court Decisions 2010Du11948, Apr. 26, 2012; 2015Du55134, Jul. 11, 2017). (2) The lower court recognized the following facts by taking into account the adopted evidence.

① Y is a private equity fund that mainly raises funds by means of private placement and creates profits through mergers and acquisitions of financial institutions or general companies whose asset value was low, purchase of non-performing loans, and investment in real estate, which was first established by M in the mid-1990s. On the completion of each investment, YI through YIV was created in the form of constituting a new fund.

(2) D. D. D. D.