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1. All of the plaintiff's claims are dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. In the case of Artificial Indones Co., Ltd., Ltd., Ltd. (hereinafter “Indonescom”), around June 18, 1987, it is the unlisted company established with capital of KRW 150 million and total issued stocks of KRW 30,000 per share ( KRW 5,000 per share).
B. Around December 31, 1999, B acquired 7,296 shares out of the above shares (24.32%) and C acquired 4,104 shares out of the above shares (13.68%) in the name of the Plaintiff through each title trust.
C. Thereafter, around May 9, 2001, Indones Constition offered capital of KRW 500 million and KRW 5,000 per share of KRW 100,000 (one share). As above, B acquired shares of KRW 24,320 in proportion to each share held in title trust to the Plaintiff, and C completed the transfer of ownership in the name of the Plaintiff on June 30, 201.
(hereinafter the Plaintiff’s shares with capital increase issued in the name of the Plaintiff (hereinafter “instant shares”).
The director of the Seoul Regional Tax Office confirmed that the issue shares are held in title by the plaintiff, after conducting a tax investigation on the certification container from January 9, 2013 to April 2, 2013, and notified the defendant of the taxation data.
E. On July 9, 2013, the Defendant assessed the value per share as of June 30, 2001 (transfer date) under the supplementary assessment method stipulated in Article 63(1)1(c) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 6780, Dec. 18, 2002; hereinafter “former Inheritance Tax Act”) on the issue stocks deemed donated under Article 41-2 of the former Inheritance Tax and Gift Tax Act, as of June 30, 201, based on the supplementary assessment method stipulated in Article 63(1)1(c) of the former Inheritance Tax and Gift Tax Act, and imposed each disposition imposing KRW 134,214,710 on the shares held in title by B as shown in the following table, and imposing KRW 68,495,70 on the shares held in title by C.
(A) Each of the above dispositions shall be referred to as "each of the above dispositions". On June 30, 2001, B24,320 B24,320 18,090 439,948,800,214,710 C 13,680 247,471, 200 68,495,770 total 38,497,420,420,000 687,420,000 202,710.