2. The grounds for use of this part of the reasoning of the judgment of the court of first instance as follows are as stated in Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, except for adding the following judgments as to the contents asserted by the plaintiff in the court of first instance to the corresponding part. As such, this part of the reasoning for use of this part of the judgment of the court of first instance is acceptable.

[Supplementary part] The Inheritance Tax Act of 9th 17th 100 in the first instance judgment is amended to be the "tax liability of deemed acquisition tax by the oligopolistic shareholder".

Pursuant to 10th 10th 10th 10th 10th 10th 10th 201, the "Seoul 201" is "Seoul 201."

The grounds of the judgment of the first instance court are as follows.

F. The Plaintiff’s assertion as to the Plaintiff’s assertion as to Article 1(4) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 20621, Feb. 22, 2008; Presidential Decree No. hereinafter “former Enforcement Decree of the Inheritance Tax and Gift Tax Act”).

There is no evidence to deem that there is no reason in the subparagraphs of Article 54(4), and it is also difficult to deem that the assessment method of the value of the instant shares should be applied mutatis mutandis because it is unreasonable to evaluate the value of the instant shares by the weighted average of the net value of net profit and loss and the net asset value in accordance with Article 54(1) of the Enforcement Decree solely on the ground that there is a significant change in the operating profit between 200 and 2004.

Therefore, the value of the instant shares is limited to net asset value in accordance with Article 54(4) of the former Enforcement Decree of the Inheritance and Gift Tax Act.