A. On September 1, 2007, the Plaintiff, which was a business of manufacturing and selling automobile parts, manufacturing and processing of fibers, etc., was established by spin-off of the original parts and the original parts processing sector among the Plaintiff’s business, and then transferred 2,800,000 shares (hereinafter “FNC sexual harassment”), which are affiliates and stock-listed corporations (hereinafter “FNC sexual harassment”), to the Haxx. The Plaintiff transferred 2,80,000 shares (hereinafter “instant shares”).

B. On August 3, 2008, 2008, 2008, 200% of 20% of 200% of 20% of 30% of 30% of 30% of 40% of 30% of 30% of 40% of 30% of 40% of 30% of 30% of 30% of 300, 2008, 200 of 6,533 won and 4,570 won of 30% of 30% of 30% of 30% of 300 and 1:69525 of 10.

C. Meanwhile, under Article 63 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9269, Dec. 26, 2008; hereinafter the same), KFM and HTT evaluated the value of the instant shares as KRW 22,941 by adding 30/100 to the average value of the closing price at the Korea Exchange published every two months before and after the appraisal base date, respectively.

As a result of a survey on stock changes in KFM, the Central Tax Office: (a) assessed the instant shares held by HFM, a merged corporation, pursuant to the former Inheritance Tax and Gift Tax Act, without evaluating the instant shares as the final market price at the Korea Exchange on the appraisal base date; (b) determined that the merger ratio of HFE was excessive; and (c) determined that the related corporation, a shareholder of the merged corporation, apportioned the profits of KRW 4,83,00,000, and notified the Defendant.

E. The defendant