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1. On April 24, 2015, the Defendant’s refusal to make a request for reduction of KRW 2,642,214,38 of inheritance tax against the Plaintiffs.
Reasons
Details of the disposition
The Plaintiffs, as co-inheritors of the president of the G Group, who died on March 10, 2013 (hereinafter referred to as “base date for appraisal”), were jointly and severally liable for payment. The Plaintiffs’ inherited property includes 913,112 non-listed shares issued by H (hereinafter referred to as “H”).
H held 2,122,642 shares issued by I Co., Ltd. (hereinafter referred to as “I”), a domestic unlisted corporation (hereinafter referred to as “I”), and held 4.5% shares of J Co., Ltd. (hereinafter referred to as “J”) and convertible bonds.
On September 30, 2013, the Plaintiffs reported and paid inheritance tax base of KRW 137,349,808,240 to the Defendant as KRW 306,559,260,369. At the time, the Plaintiffs assessed the value of shares as KRW 137,349,80,240 according to the supplementary assessment method prescribed in Article 63(1)1(c) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11690, Mar. 23, 2013; hereinafter “former Inheritance Tax Act”). In calculating the net asset value of the shares at issue, I issued stocks are assessed as KRW 89,256 per share in accordance with the supplementary assessment method prescribed in Article 63(1)1(c) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11690, Mar. 23, 2013; hereinafter “former Inheritance Tax Act”).
From September 15, 2014 to December 19, 2014, the Seoul Regional Tax Office conducted an inheritance tax investigation with respect to the Plaintiffs, and notified the Defendant of taxation data. On January 7, 2015, the Defendant adjusted the tax base on January 7, 2015 to KRW 308,337,365,052, and then additionally determined and notified the Plaintiffs of the inheritance tax amounting to KRW 993,064,280 (including additional tax).
It is the amount calculated by deducting the appraised value of the inherited property from KRW 81,50,724,672 at the time of reporting the issue shares (related to I issued shares) and KRW 77,127,831,304 at the time of evaluating I issued shares as zero won.
2,186,446,684 ② Inherited property at the time of reporting 761,535,408 of the issue shares (related to shares issued by J and convertible bonds).