1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning of the judgment of the court of first instance cited the following among the reasons for the judgment of the court of first instance, and the fact-finding and judgment of the court of first instance are justifiable even if the plaintiff added the evidence submitted to this court, and it is identical to the reasons for the judgment of the court of first instance except for the cases where the plaintiff added the judgment that there is no error as alleged by the plaintiff, and thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of

5 pages 2 are as follows: "The Restriction of Special Taxation Act (amended by Act No. 16009, Dec. 24, 2018; hereinafter the same shall apply)" is the former Restriction of Special Taxation Act.

13 Myeon 5 and 6 of the Restriction of Special Taxation Act shall be applied to the "Gu Restriction of Special Taxation Act".

13. The part of the 8th page “N” to “N” up to 10th page “N” was read as “in order to lower the trading ratio of a person with special interest, such as the Plaintiff, in the course of the transaction with a view to lowering the trading ratio of a person with special interest with a view to evading the gift tax of a controlling shareholder.”

After the second parallels 14, “(6) Seoul High Court Decision 2017No504 Decided August 9, 2017 cited by the Plaintiff is different from the instant case, and thus, it is inappropriate to invoke the instant case.”

The 15th parallel of the 15th parallel is that it seems to be merely an act for the legitimacy of the law."

In 16, two pages "The Value-Added Tax Act (amended by Act No. 14387, Dec. 20, 2016)" are higher than the former Value-Added Tax Act.

16. The Restriction of Special Taxation Act of 21 pages shall be applied to the "Gu Restriction of Special Taxation Act".

2. In conclusion, the plaintiff's claim of this case is dismissed as it is without merit, and the judgment of the court of first instance is just in conclusion, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.