1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasons why this court should explain concerning this part of the disposition are as follows: (a) the part concerning “total amount of KRW 291,650,230” in the second 8th of the judgment of the court of first instance as “total amount of KRW 291,650,230” (hereinafter “instant appraisal value”) is identical to the part concerning the second 1 through 16th 16 of the relevant part of the grounds for the judgment of the court of first instance; and (b) therefore, it is cited in accordance with Article 8(2) of the Administrative Litigation Act, the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. Article 97(1)1(b) of the relevant Act and subordinate statutes provides that “Where the actual transaction value at the time of acquisition is to be “actual transaction value” and where it is impossible to confirm the actual transaction value at the time of acquisition, the transaction example value, appraisal value or conversion value prescribed by Presidential Decree.” Article 163(12) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013; hereinafter the same shall apply) provides that “The value of transaction example, appraisal value or conversion value prescribed by Presidential Decree” in Article 97(1)1(b) of the Act refers to the value stipulated in Article 176-2(2) through (4). The main sentence of Article 176-2(3) provides that “Where the transfer value or acquisition value is to be determined or revised by estimation pursuant to Article 114(7) of the Act, it shall be limited to the value calculated by applying the following methods in order to the average value before or after the date of acquisition value: