Plaintiff 1 and one other (Law Firm Sejong, Attorneys Gyeong-hee, Counsel for the plaintiff-appellant)

The Head of Gangnam District Tax Office et al.

September 2, 2004

Seoul Administrative Court Decision 2002Guhap11 delivered on November 11, 2003

1. All appeals filed by the plaintiffs and the defendants are dismissed.

2. Costs of appeal shall be borne by each person.

1. Purport of claim

The head of Gangnam-gu Tax Office imposed a gift tax of KRW 102,387,960 on March 2, 2001 on Plaintiff 1 on the ground of the gift made on May 7, 1997, KRW 97,379,460 on the ground of the gift made on May 28, 1997, KRW 66,940,150 on the ground of the gift made on December 30, 197, and KRW 183,583,750 on the ground of the gift made on December 27, 1998 (it appears that it was erroneous that Plaintiff 1 written on April 21, 2001 as the date on which the claim for the gift was made on April 21, 2001, KRW 187, KRW 200 on the ground of the gift made on the ground of the gift made on May 28, 2001, KRW 208, KRW 37,8197.5857.28

2. Purport of appeal

The part against the plaintiffs in the judgment of the court of first instance shall be revoked. The imposition of gift tax of KRW 102,387,960 on the ground of the gift as of May 7, 1997, KRW 97,379,460 on the ground of the gift as of May 28, 1997, KRW 66,940,1590 on the ground of the gift as of December 30, 1997, and the imposition of gift tax of KRW 33,158,620 on March 1, 200, KRW 208, KRW 280 on the ground of the gift as of May 7, 1997, and KRW 33,158, KRW 620 on the ground of the gift as of May 28, 197, KRW 208, KRW 868, KRW 180 on the ground of the gift as of December 30, 1997.

Defendant: The part of the first instance judgment against the Defendants shall be revoked, and the Plaintiff’s claim corresponding to that part shall be dismissed.

The reasoning of this court’s reasoning is as follows: (a) the reasoning of the judgment of the court of first instance is as stated in the column of the reasoning of the judgment of the court of first instance, except where “ April 21, 2001” in Section 3, Section 16 of the judgment of the court of first instance is deemed to be “ March 2, 2001,” and thus, it is cited by applying Article 8(2) of the Administrative Litigation Act, the main text of Article

Therefore, the judgment of the first instance is legitimate, and all appeals filed by the plaintiffs and the defendants are dismissed.

Judges Park Jong-soo (Presiding Judge)