The director of the regional tax office (the chief of the Sungnam Tax Office prior to the correction) set forth the No. 4 of the attached Table 1 taxation details against the plaintiff D.

The reasoning of the judgment of the court of first instance is as follows, and the reasoning of the judgment of the court of first instance is identical to that of the court of first instance, except for the parts to be determined additionally in the following paragraphs, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the

The term "In Gyeyang-gu Seoul Metropolitan Government K" in the 3th and the 5th place shall be changed to the 5th floor of Seongbuk-gu Seoul S building.

The term " January 25, 2006" in the third 8th place shall be read as " January 6, 2006".

The number and shareholding ratio of shares from September 15, 2009 to December 31, 2009 from September 15, 2009 to December 31, 2009, respectively, shall be "4,975 Shares" and "49.75%".

The defendants in the 6th second place are "the defendant (the defendant in the Sungnam Tax Office before the correction for the plaintiff D)".

6 The term "19,689,862,646 won" shall be read as "19,343,85,660 won".

13. The “each month’s maturity” of the last end line shall be deleted.

14 The phrase “The Evidence 20 to 25 of A” referred to as “the Evidence 13 to 25 of A” shall be understood as “the Evidence 13 to 25 of A.

Attached Form 2 "Related Acts and subordinate statutes" shall add the part of the relevant Acts and subordinate statutes in this judgment.

Additional Determination

A. The Defendants asserted 1) pursuant to the principle of substantial taxation under the Inheritance and Gift Tax Act, the increase in the value of shares in J may be deemed as the value of donated property pursuant to Article 2(3) of the Inheritance and Gift Tax Act, even in cases where the value of donated property can be assessed by objective and reasonable evaluation methods without applying Articles 32 through 42 of the Inheritance and Gift Tax Act. As such, in applying Article 42(1)3 of the Inheritance and Gift Tax Act, the value of donated property to the Plaintiffs may be calculated by applying Article 42(1)3 of the Inheritance and Gift Tax Act. 2) Even if the increase in the value of shares in J cannot be calculated as the value of donated property immediately after the change in the value of shares of N, etc. owned by the Plaintiffs due to the instant donation, and thus, the economic interest between the Plaintiffs is gratuitously transferred.