1. Of the judgment of the court of first instance, the part against Plaintiff A, which orders the cancellation below, shall be revoked.

1. The reasons for the court’s explanation concerning this case are as follows: (a) the part of the first instance judgment, i.e., Articles 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act, i.e., the part concerning the reasons for the first instance judgment, other than the part to be determined additionally as follows, are deleted.

2. Additional determination

A. Determination on the assertion that the appraisal value should be deemed the market price. 1) The gist of the Plaintiffs’ assertion that the appraisal value as well as other property may be deemed the market price if it is objective and reasonable. According to the statement of stock value assessment report (No. 15-1 and No. 2), the appraisal value per share of the non-party company is KRW 29,158, and KRW 9,823, Sept. 15, 2010. Thus, the Defendant’s disposition of this case, which calculated and imposed the appraisal value per share, is unlawful. 2) In view of the fact that Article 49(1)2 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 22579, Dec. 30, 2010; hereinafter “Enforcement Decree of the Inheritance Tax and Gift Tax Act”), barring special circumstances, the method of calculating the market price of non-listed shares is not different from the market price of non-listed shares under the former part of Article 60(2) of the Inheritance Tax and Gift Tax Act.