The propriety of this disposition with respect to the value stated in the exchange contract

As long as the actual transaction price is revealed through a stock transfer contract, etc., it is sufficient to impose tax based on it, and the standard market price cannot be applied.

Article 96 of the Income Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

Although the lower judgment was examined in light of the records of this case, it is recognized that the assertion on the grounds of appeal falls under Article 4 of the Act on Special Cases Concerning Procedure

Therefore, the appeal is dismissed in accordance with Article 5 of the above Act. It is so decided as per Disposition by the assent of all participating Justices on the bench.