Whether the export loss reserve and overseas market development reserve prescribed in Articles 22 and 23 of the Regulation of Tax Reduction and Exemption Act fall under the liabilities to be deducted from the net asset value of the corporation in calculating the net asset value of the corporation concerned in order to calculate the value of stocks not listed on the Stock Exchange at the time of commencing the inheritance.

2. The defendant asserts that the taxation disposition in this case is legitimate on the grounds of the above taxation grounds and applicable provisions of law. The plaintiffs asserted that the export loss reserve and overseas market opening reserve included in deductible expenses in calculating the income amount under Articles 22(3) and 23(3) of the Regulation of Tax Reduction and Exemption Act shall include the amount calculated by dividing the reserves by 36 years (five years for export businesses as prescribed by the Presidential Decree) after the end of the taxable year which includes the taxable year in which the reserves are included in deductible expenses ± the amount calculated by multiplying the number of months in the taxable year concerned by the number of months in the taxable year concerned ± 400,660, and 485 won included in deductible expenses in calculating the income amount in the taxable year concerned, the non-party company's above 20,198, 145 won, defense tax 】 24,639, 294, 2505, 260, 3605, 250, 360, 465

The first sentence of Article 9(1) of the Inheritance Tax Act provides that the value of inherited property, the value of inherited property, the value of donated property to be added to the value of inherited property, and the value of inherited property shall be based on the current status as at the time of commencement of inheritance. Article 5(1) of the Enforcement Decree of the same Act provides that the value according to the current status as at the time of commencement of inheritance provided for in Article 9 of the Act or the value as at the time of imposition of inheritance tax shall be calculated based on the method provided for in paragraphs (2) through (5) if it is difficult to calculate the market price at the time of commencement of inheritance. Article 9(5) of the same Act provides that the value of securities shall be assessed according to the method provided for in subparagraph 1(b) (B) of the same Article (which is before the revision of December 31, 198) and the net asset value of the corporation shall be calculated by deducting the net asset value of the corporation at the time of commencement of inheritance from the net asset value of the corporation at the time of commencement of inheritance.

Therefore, corporate tax to be imposed on the export loss reserve funds and overseas market opening expenses; health expenses to be imposed on the non-party 1, resident tax and defense tax corresponding thereto; Articles 22(1) and 23(1) of the Regulation of Tax Reduction and Exemption Act provide that if the export loss reserve funds and overseas market opening reserve funds are appropriated as losses in order to cover the expenses for the loss incurred from the foreign exchange earnings business; and Articles 22(2) and 23(2) of the same Act provide that if losses incurred from the overseas exchange earnings opening reserve funds or incurred from the overseas market opening expenses or incurred from the overseas market opening expenses for the same year after such inclusion in deductible expenses, the amount of such losses or expenses may be offset as long as the amount of income for the non-party 2, including the export loss reserve funds and overseas market opening expenses for the above year after such inclusion in deductible expenses, and Articles 22(3) and 23(3) of the same Act provide that the amount of income for the non-party 1, which would still be included in deductible expenses for the year concerned, within two years after such inclusion in deductible expenses.

3. Therefore, the plaintiffs' claims of this case seeking revocation on the premise that the defendant's taxation disposition against the plaintiffs is illegal, are without merit, and each of the costs of lawsuit is dismissed and decided as per the disposition by the plaintiffs as the losing party.