The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

The lower court held that the Defendant’s assessment of the value per share of the K stocks of an unlisted company in a foreign country in accordance with the supplementary assessment method is unlawful on the grounds that there is insufficient evidence to support that it is inappropriate to assess the shares of the K, an unlisted company, as a subsidiary of G, based on the supplementary assessment method, only when it is not appropriate to apply the supplementary assessment method stipulated in Article 54 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 20621, Feb. 22, 2008).

The judgment below

In light of the relevant legal principles and records, the judgment of the court below is just and acceptable. Contrary to the allegations in the grounds of appeal, there were no errors in the misapprehension of legal principles as to the application of supplementary evaluation methods to overseas unlisted stocks.

The remaining grounds of appeal are with respect to the lower court’s additional judgment, and so long as the lower court’s determination that the Defendant’s appraisal of K shares was unlawful is justifiable, the legitimacy of the assertion cannot affect the conclusion of the judgment, and thus, it cannot be accepted without the need to separately determine

Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.