Whether special profits and losses should be reflected in the valuation of net profits and losses of unlisted stocks;

In cases where the weighted average amount of special profit and loss in accordance with corporate accounting standards for the last three years exceeds 50% of the weighted average amount of ordinary profit and loss in the last three years, the weighted average amount of net profit and loss in the last three years per share shall not be the weighted average amount of net profit and loss in the last three years, except in exceptional circumstances.

Paragraph (1) of Article 56 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act shall apply to the method of calculating net profits and losses for the last three

1. The defendant's appeal is dismissed.

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

1. Purport of claim

The defendant's disposition of imposition of KRW 637,851,200 on March 2, 2004 against the plaintiff shall be revoked.

2. Purport of appeal

The judgment of the first instance is revoked. The plaintiff's claim is dismissed.

1. Acceptance of the judgment of the first instance (Seoul Administrative Court Decision 2005Guhap18068 delivered on December 22, 2005);

The reasons why a member states on this case are the same as the reasons for the judgment of the court of first instance, and thus, they are cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

2. Conclusion

Therefore, the judgment of the first instance court is legitimate, and the defendant's appeal is dismissed. It is so decided as per Disposition.