1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the court’s explanation concerning this case is as stated in the judgment of the court of first instance, except for the dismissal or addition of the text of the judgment of the court of first instance as follows. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

In the first instance judgment, the first instance judgment, which found “(6)” to be “D,” and added the following contents to “no grounds” under the third instance judgment following the third instance judgment ( Even if the Plaintiff: (a) established B while the Deceased was in arrears with the amount of 45 million won, national taxes, etc.; and (b) made a title trust with the Plaintiff on January 18, 2000, it is reasonable to limit the purpose of tax avoidance to the taxes that may arise after the title trust; (c) therefore, it is unreasonable to accelerate the purpose of tax avoidance on the grounds of the deceased’s delayed national taxes, etc., and (d) in the case of capital increase for the purpose of tax avoidance conducted from June 1, 201 to June 9, 2001, the Plaintiff asserted that there was no purpose of tax avoidance. However, the Plaintiff’s assertion that there was no intention to avoid tax payment due to the delinquent tax evasion purpose in the title trust donation, and that there was no attempt to maintain the deceased’s tax evasion relationship with the deceased’s death.

2. In conclusion, the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed as it is without merit.