Seoul High Court 2012Nu7587 (Law No. 18, 2013)

2011 Heavy0786 (201.06.03)

(C) In calculating the "value of assessment per share before the capital increase", it shall be calculated on the basis of the payment date of the stock price.

In light of the fact that if the date when the period of protection expires as the evaluation base date, the value of the donated property is likely to change depending on the intention of the parties, it is reasonable to calculate the value of the donated property per share before the capital increase in order to calculate the value of the donated property even when the new shares for which the period of protection is set in the issuance of new shares with the third party allocation method are allocated.

2013Du6459 Revocation of Disposition of Imposition of Gift Tax

jAA

Head of Sungnam Tax Office

Seoul High Court Decision 2012Nu7587 Decided January 18, 2013

The appeal is dismissed.

The plaintiff shall bear the costs of appeal.

All of the records of this case and the judgment of the court below and the grounds of appeal are examined, but the appellant's grounds of appeal are not included in the grounds provided for in each subparagraph of Article 4 (1) of the Special Cases Concerning the Appeal Procedure. Accordingly, the appeal is dismissed pursuant to Article 5 of the same Act, and the costs of appeal are assessed against the losing party. It is so decided as per

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final