1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1..

1. The reasoning of the judgment of this court, such as accepting the judgment of the court of first instance, is as stated in the reasoning (except for the amendment of the pertinent part of the judgment of the court of first instance as follows 2). Therefore, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. The amended part of the 7th parallel "1,627,563,125 won" shall be deemed "1,627,563,225 won".

2 Under 2, the term “Presidential Decree No. 14389” shall be read as “Presidential Decree No. 27829”.

3. The phrase “as above” shall be deleted from 10 parallels.

4 At the right side of the "Evaluation Method" (hereinafter referred to as "Supplementary Evaluation Method under the Inheritance and Gift Tax Act") shall be added to the "Evaluation Method".

The 4th to 8th 9 acts asserts to the effect that "shall be assessed" are as follows.

【Evaluation. This case’s exchange contract argues that the Plaintiff’s transfer of assets to a related party at a price lower than the market price is deemed to have reduced the tax burden unfairly and thus subject to the avoidance of wrongful calculation pursuant to Article 101(1) of the former Income Tax Act and Article 167(3)1 of the former Enforcement Decree of the Income Tax Act. The Plaintiff determined that “the instant stock and exchange real estate should be subject to the avoidance of wrongful calculation.” The Plaintiff did not undergo a market price appraisal, etc. to separately calculate the objective value of the instant stock and exchange real estate.”

The 5th day below shall be from 5 to 6th day below, as follows:

A person shall be appointed.

C. According to the method of calculating the transfer value of the instant shares (1) under the former Income Tax Act and the Enforcement Decree of the same Act, the transfer value of unlisted stocks shall be the actual transaction value between the transferor and the transferee at the time of transfer of the relevant assets, i.e., the actual transaction value (Articles 94(1)3 (b) and 96(1) of the former Income Tax Act), and a contract receipt necessary to confirm the actual transaction value at