1. The judgment of the court of first instance is modified as follows.

The gift tax imposed on the Plaintiff on December 1, 2016 by the Defendant on the Plaintiff on December 1, 2016 is 925,494.

1. The reasoning of the judgment on the grounds of this part of the disposition is identical to the corresponding part of the judgment of the first instance, except for the modification as follows, and thus, this part of the judgment is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of

The following was added under the 2nd six parallels, and, on the other hand, C had a trade name change or spin-off as follows. On September 1, 2012, 2012, the surviving corporation: A corporation: (a) on September 28, 2012, 2012, the surviving corporation: (b) a corporation established a spin-off division for the mutual change of the trade name of a plan for the resolution of the resolution of the resolution of the resolution of the mutual savings bank: (c) a corporation established a corporate division for the mutual change of the company: (d) a corporation:

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) In calculating the net value per share of the instant shares, it is reasonable to interpret “one year prior to the evaluation base date, two years, and three years prior to the evaluation base date” as “three consecutive business years prior to the evaluation base date.” In addition, the former Enforcement Rule of the Inheritance Tax and Gift Tax Act (amended by Ordinance of the Ministry of Strategy and Finance No. 481, Mar. 13, 2015; hereinafter “former Enforcement Rule of the Inheritance Tax and Gift Tax Act”).

(2) Article 17-3(2) of the Act provides that the net profit and loss value per share shall be calculated at the value calculated as one year if the business year is less than one year. Therefore, it is unlawful to interpret “the business year before the base date of appraisal” as “the business year when the third anniversary falls before the base date of appraisal” as “the business year when the third anniversary falls before the base date of appraisal,” and to exclude the 32 business years near the base date of appraisal, and calculate the net profit and loss per share of the stocks of this case for the 31 business year, which is subject to the 31st business year. 2) The Defendant’s increase in the tax amount by revising the initial disposition in accordance with the purport of the instant adjudication decision in accordance with the purport of the instant adjudication, along with the revision of the disposition in question, for the new reason for the said new disposition, is contrary to the binding force of the instant adjudication.