1. All appeals by the Defendants are dismissed.

2. The costs of the lawsuit after the appeal shall be borne by the Defendants.

1. The reasons why this court should explain concerning this part of the disposition are as follows: (a) the part of the purchase date of Plaintiff A in the second part of the judgment of the court of first instance, with the exception of “the date of purchase of Plaintiff A” as “the date of December 2, 2003.” Thus, this part of the judgment of the court of first instance is identical to the corresponding part of the judgment of the court of first instance; and (b) under Article

2. Whether the disposition is lawful;

A. The plaintiffs 1) since they did not prepare and keep the register of shareholders under the Commercial Act, the transfer of the shares of this case at the time of the transaction of this case cannot be deemed to have been made. Thus, the former Inheritance Tax and Gift Tax Act (amended by Act No. 7010, Dec. 30, 2003; hereinafter "former Inheritance Tax Act") shall be deemed to have been made on the transaction of this case.

A) The deemed donation of title trust under Article 41-2(1) may not be applied to the instant transaction. Moreover, the instant transaction is subject to the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “Revised Inheritance Tax Act”).

(2) As the Defendants submitted the statement of stock change on March 30, 2004 regarding the instant transaction on or before January 1, 2004, it cannot be deemed that the change of ownership was made pursuant to the statement of stock change by applying Article 45-2(3) of the amended Inheritance and Gift Tax Act. In addition, even if the deemed donation of title trust is applied to the instant transaction, the additional payment for the erroneous payment should be calculated in an amount equivalent to 20/100 of the unpaid tax amount pursuant to Article 78(2) of the former Inheritance and Gift Tax Act. (2) The Defendants D submitted the statement of stock change on March 30, 2004 in relation to the instant transaction by applying Article 45-2(3) of the amended Inheritance and Gift Tax Act.

(P) However, D is liable to pay gift tax based on the constructive gift for title trust pursuant to Article 41-2(1) of the former Inheritance and Gift Tax Act, because D is preparing and keeping a register of shareholders at the time of the instant transaction.

(Preliminary Grounds). (b)

With respect to this part of the related laws, this Court.