1. All appeals filed by the plaintiffs are dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance regarding the instant case is as stated in the part of the judgment of the court of first instance, except for adding the judgment on the following arguments emphasized by the plaintiffs again in the trial of the court of first instance, and thus, it is acceptable to accept it as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. In addition, the Plaintiffs claim that the disposition of this case is unlawful on the grounds that “the management and disposal of the property for which an application for payment in kind is filed is deemed inappropriate” under the delegation of Article 71(1) of the Enforcement Decree of the Inheritance Tax and Gift Tax Act and Article 19(4) of the Enforcement Rule of the same Act, which is the grounds for refusal of an application for payment in kind, is limited and narrowly stipulated. It cannot be deemed an exemplary provision. The Defendant’s refusal of an application for payment in kind, that is, it is impossible to issue share certificates because the Plaintiff’s refusal of an application for payment in kind is under the process of litigation on ownership of the shares, does not correspond to any of the above provisions listed in the above cases.

However, the payment of taxes is in principle a cash payment, and the payment in kind must take into account the equity with a person liable to pay taxes in cash and the balance of tax collection as an exception, and in the case of payment in kind, the collection of taxes is ultimately realized through realization, such as the sale of an asset in kind, so that an application for payment in kind for an asset, the management of which is inappropriate under the proviso of Article 73(1) of the Inheritance Tax and Gift Tax Act may be refused. "Where the management and disposal of an asset is inappropriate," there are many cases due to not only the nature of the asset itself, but also the individual situation surrounding the asset.