1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The grounds for admitting the judgment of the court of first instance are as stated in the reasoning of the judgment of the court of first instance. Thus, the grounds for admitting this case are as stated in Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

[The plaintiff repeats the same argument in the first instance court to the effect that "the fact that the plaintiff sold the stocks of this case to the non-party company at KRW 6,153 per share under the conditions as stipulated by the articles of incorporation is illegal, even though it was a normal transaction in accordance with the market price, the disposition of this case that the defendant denied it and assessed the value in accordance with the supplementary assessment methods is unlawful." Thus, even if considering the allegations and the reasons that the plaintiff partly supplemented and additionally submitted the plaintiff, each statement of evidence Nos. 5, 6, and 7 (including the serial number) is taken into account, the stock transaction in this case is a transaction between related parties, and it cannot be deemed that the plaintiff properly reflects the objective exchange value, and thus, it cannot be deemed as the market price. Accordingly, the judgment of the court of first instance rejecting the plaintiff's argument that the defendant calculated the transfer value by applying the provisions of the unfair calculation panel under the Income Tax Act by assessing the value per share of this case as 12,522 won is justifiable."

2. In conclusion, the plaintiff's claim of this case is dismissed as it is without merit, and the judgment of the court of first instance is just in conclusion, and the plaintiff's appeal is dismissed.