1. Revocation of a judgment of the first instance;

2. The Defendant’s inheritance tax amounting to KRW 2,863,697,160 against the Plaintiff on March 10, 2014.

1. The reasoning for the court’s explanation on this part is as follows: (a) except where the second and sixth judgment of the court of first instance “O. 30, 2013” is deemed to be “O. 30, 2013.” and the relevant part of the grounds for the judgment of the court of first instance is the same as that of the relevant part of the judgment of the court of first instance; and (b) thus, the same shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and

2. Whether the instant disposition is lawful

A. On the grounds delineated below by the Plaintiff, the instant disposition that the Defendant calculated the weighted average amount of net profit and loss per share based on the instant shares under Article 56(1)1 of the Enforcement Decree of the former Inheritance and Gift Tax Act based on “the weighted average amount of net profit and loss per share for the last three years” should be revoked as it is unlawful.

1) Since there is a “business example” for the instant shares, the supplementary evaluation method of unlisted stocks under the Inheritance Tax and Gift Tax Act cannot be applied to the valuation of the shares per share of the instant shares, and the said value shall be followed. 2) Even if the supplementary evaluation method of unlisted stocks under the Inheritance Tax and Gift Tax Act is applied in view that no objective business example exists with respect to the shares of this case, even if the Plaintiff’s husband, who was operating the instant company as an expert in the paper money industry, died on July 15, 2012, was in charge of the instant company. In light of such circumstances, the instant shares constitute “a corporation’s shares deemed difficult to continue business due to the death, etc. of the business operator within the deadline for the return of the inheritance tax base” under Article 54(4) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act, and should not reflect the net asset value and evaluate only “net asset value.”

3 Even if the net profit and loss value is reflected in the application of the supplementary evaluation method of unlisted stocks under the Inheritance and Gift Tax Act, the company of this case, even if the D farm was expropriated around July 201, and E farm was sold around April 2012, the total size of the farm was reduced to 1/2, and the outbreak and government of the 201 foot relief station.