1. All appeals filed by the plaintiffs and the defendant Ansan Tax Office are dismissed.

2. The costs of appeal shall be borne respectively by each party.

1. The reasoning of the judgment of the court of first instance is the same as the reasoning of the judgment of the court of first instance, except for the dismissal or addition of the following contents among the grounds of the judgment of the court of first instance. Therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

① Part 6, Paragraph 2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “Gift”) is amended as “former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 20621, Feb. 22, 2008; hereinafter “Inheritance Tax Act”)”.

(2) The number of pages 9, 11, "for a subsidiary" shall be adjusted to "for a subsidiary".

(3) The 3rd page "subsidiary" shall be improved to "for assets of the subsidiary".

4. Part 10 "105,546,527 HK$3,00,000 for HK$ 105,56,527."

⑤ In calculating the value per share of K, a foreign subsidiary, there is no evidence to acknowledge “whether it is inappropriate to make an assessment by a supplementary assessment method under Article 54 of the Enforcement Decree of the Inheritance and Gift Tax Act” in Section 6 of Chapter 11, the head of the competent tax office, the head of the competent tax office, and the head of the competent tax office, the head of the competent tax office, as the market interest rate in Hong Kong is lower than the Republic of Korea. As such, in calculating the net profit and loss value based on the domestic interest rate, the net profit and loss would be reduced when calculating the net profit and loss value, and the Plaintiff’s donated property would be reduced. However, the above assertion by the head of the competent tax office, at the same time, that the supplementary assessment method under Article 54 of the Enforcement Decree of the Inheritance and Gift Tax Act should be applied to calculating the value per share of K, a foreign subsidiary, is difficult to deem that it is an “when it is not applied”

6. On the 11th page “illegal”, the Defendant’s evaluation of the stock value of K in the supplementary evaluation method, and each business year’s income in the 2002, 2003, and 2004, respectively, shall be 665,350,350 HK dollars, 6,903, 257H$, and 26.