1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The defendant's grounds for appeal citing the judgment of the court of first instance are not significantly different from the argument in the court of first instance, and if the evidence submitted in the court of first instance shows additional evidence submitted in this court, the fact-finding and judgment of the court of first instance are justified.

Therefore, the reasoning of the judgment of the court on the instant case is as stated in the reasoning of the judgment of the court of first instance, except where the defendant stressed or added the judgment on the new argument by the court as the grounds of appeal and added the judgment in Paragraph 2, and thus, it is acceptable to accept it as it is in accordance with Article 8(2) of the Administrative Litigation Act and the text

2. Additional determination

A. The summary of the Defendant’s grounds for appeal before being amended by Act No. 14388, Dec. 20, 2016 of the former Inheritance Tax and Gift Tax Act

c. Article 2(1) of the former Inheritance and Gift Tax Act

(1) Article 60(1) and (2) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 27205, May 31, 2016)

A. The Enforcement Decree of the former Inheritance and Gift Tax Act (hereinafter “former Enforcement Decree of the Inheritance and Gift Tax Act”).

In full view of the provisions of Article 49(1)1, in the case of unlisted stocks, the market price as of the commencement date of the inheritance is to be the value of the property on which the inheritance tax is levied. In the case of unlisted stocks, where there is a sale of the pertinent property (non-listed stocks) during the period of six months before or after the commencement date of the inheritance (the commencement date) in determining the market price, the transaction price shall be deemed the market price. In this case, the “transaction” made between H and I on September 23, 2016 constitutes a sale of the instant corporate stocks conducted within six months after the commencement date of the inheritance (the commencement date of the inheritance) of the instant case, and thus, the transaction price of the instant stocks shall be deemed the market price at the evaluation date (the market price at the time of the commencement of the inheritance) under the relevant provisions.

Therefore, the disposition of this case is lawful when the market price at the time of the commencement of the inheritance of this case is calculated as KRW 5,000 per share, which is the transaction price of this case.

The transaction value of this case is old.