Whether the combined shares are included in the liquidation income;

Whether the amount equivalent to the combined stocks included in the cost of merger is included in the amount of liquidation income under the Corporate Tax Act or not subject to taxation or subject to reduction or exemption.

Article 80 (Calculation of Liquidation Income Amount due to Merger of Corporate Tax Act)

1. The plaintiff's appeal is all dismissed.

2. Costs of appeal shall be borne by each person.

1. Purport of claim

The Defendant’s disposition of imposition of KRW 638,097,284 and additional tax 63,809,728 against the Plaintiff on March 2, 2004 is revoked.

2. Purport of appeal

Of the judgment of the court of first instance, the part against the plaintiff shall be revoked. The defendant's disposition of imposition of KRW 638,097,284 on March 2, 2004 against the plaintiff shall be revoked.

The judgment of the court of first instance is revoked. The plaintiff's claim corresponding to the above revocation is dismissed.

1. Quotation of judgment of the first instance;

The reasoning of the judgment of this court is the same as that of the judgment of the court of first instance, and thus, it is accepted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Conclusion

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