Whether a stock evaluation value per stock is reasonable at the time of stock evaluation by supplementary evaluation methods under the Inheritance Tax Act;

In assessing the value of shares, there was an error of calculating the net asset value of ○○ Insurance, which is an incidental insurance, by zero, and in calculating the weighted average amount of net profits and losses for the last three years per share, it is illegal disposal because it did not properly record the base date.

Seoul Administrative Court 2005Guhap36684 (Law No. 24, 2006)

Donation of property registered in the name of a third party under Article 32-2 of the former Inheritance Tax Act;

1. The defendant's appeal is dismissed.

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

1. Purport of claim

Each imposition of KRW 2,829,187,290 on the ground of the gift made by the Defendant against the Plaintiff on January 13, 1993 and KRW 1,020,95,670 on the ground of the gift made on April 12, 1993 shall be revoked.

2. Purport of appeal

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

1. Quotation of judgment of the first instance;

This court's reasoning is the same as the entry in the column of reasoning for the judgment of the court of first instance. Thus, it is citing it as it is in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420

2. Conclusion

Therefore, the judgment of the first instance court is legitimate, and the defendant's appeal is dismissed as it is without merit. It is so decided as per Disposition.