Whether the difference between the acquisition price of new stocks under the conditions of protection and the market price can be deemed a deemed donation.

Since the validity of a juristic act of acquiring shares cannot be deemed to depend on the gender of an uncertain fact in the future, it does not constitute conditional rights under the Inheritance Tax and Gift Tax Act, and the amount equivalent to the difference allocated by a third party at a price lower than the market price of new shares constitutes the benefits donated.

Donation under Article 39 of the Inheritance Tax and Gift Tax Act

Article 63 of Inheritance Tax and Gift Tax Act: Appraisal of Securities

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

We examine the grounds of appeal.

The court of final appeal may examine and determine only to the extent of filing an appeal based on the grounds of final appeal. As such, the grounds of final appeal need to specify the grounds of final appeal and explain specific and explicit reasons as to which part of the judgment below violated the law. However, the plaintiff does not indicate such specific grounds of final appeal in the appellate brief of this case, but only criticizes the judgment below abstractly, such reasons alone cannot be a legitimate ground of final appeal.

Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices on the bench.