2. The costs of lawsuit are assessed against the plaintiffs.

A. On July 1, 2008, the Plaintiffs assessed the right to sell the instant apartment units (hereinafter referred to as “instant apartment units”) under the OOOO apartment 00 00 000 dong O200 (hereinafter referred to as “the instant apartment unit”) that was reconstructed at the time of inheritance on December 31, 2010, and paid inheritance tax by evaluating the sum of the appraised value of OOOOOO apartment 00 00 00 m2000 m2000 and 58.08 m2 (hereinafter referred to as “the previous apartment”).

B. The director of the Seoul Regional Tax Office confirmed on June 24, 200 that there was a example of business transaction in the sale right of 00 dong 000 dong 000 dong 000 (hereinafter referred to as a "multi-party apartment") located in the same apartment complex as the apartment complex of this case (hereinafter referred to as "non-party 1 apartment house") within the evaluation period of inherited property, and ordered the defendant to dispose of KRW 000,000, which is the sale price of the above sale right, as the market price of the sale right of this case. Accordingly, on January 12, 2001, the defendant assessed the sale transaction example right of this case at KRW 00,000, and notified the defendant of KRW 138,834,530 in around 20.

C. The Plaintiffs were dissatisfied with the disposition of the instant case and filed an appeal with the Tax Tribunal on March 18, 201, but the Tax Tribunal dismissed the appeal on October 28, 201.

[Grounds for Recognition] The entire arguments, as described in the facts without dispute, Gap 1, 2, 5, 7, and 1, 2, and 3 (including household numbers), and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiffs' assertion

① The transaction example example of the comparative purchase right was only one transaction example, and it was confirmed only within the National Tax Service, so it is impossible for the Plaintiffs to confirm the transaction example. The apartment of this case and its location are different from that of the apartment of this case, and the transaction price of the comparative purchase right cannot be deemed the market price of the sales right of this case, and even if not, the Plaintiffs were not aware of the market price of the sales right of this case, the penalty tax imposition part of the disposition of this case is unlawful.

B. Relevant statutes

Entry in the attached Form.

C. Facts of recognition

1) The difference between the value of the sales right of this case and the sales right of this case is as follows.

2) The area and the highest number of floors and direction of the subject apartment and the comparable apartment are the same, and in the location of the apartment in this case, the apartment in this case is located on the central side of the complex, and the comparable apartment is located at the edge of the side of the road.

[Ground of Recognition] The facts without dispute, Gap 4, Eul 6, Eul 7, and Eul 4 (including household numbers), and the purport of the whole pleadings

D. Determination

1) Whether the computation of the market price is lawful

In full view of the above facts, the following history, that is, the apartment of this case and the comparable apartment, which are recognized as having been combined with the whole purport of the pleading, are different in the number of floors and location, but because the area, location, number of floors, structure, etc. are identical or similar to the same apartment in the same complex, the sales right of this case and the comparable right are also identical. In light of the fact that the standard market price of the apartment of this case at the time of April 30, 2009 was higher than the standard market price of the comparable apartment, and that the inheritance date of the sales right of this case is one week after the date of sale of the comparative apartment, it is deemed appropriate that the sales price of the comparative right is ordinarily established if the sales right of this case is freely traded between many unspecified persons at the time of the commencement of the inheritance, and on the other hand, it is difficult to deem that the market price is unlawful, and that the sales price of the comparative right is calculated as the market price of the sales right of this case.

2) Whether the imposition of penalty tax is lawful

A) In light of the fact that an additional payment for inheritance tax is a financial benefit for inducing a taxpayer to pay the tax in good faith, and that the amount paid by the due date for payment is an administrative sanction imposed on the violation of the obligation to pay the tax, it cannot be said that even if the amount is a tax unpaid due to a difference in the appraisal of the value of donated property, it is not subject to the imposition of additional tax for unfaithful payment (see Supreme Court Decision 2007Du23200, Jan. 14, 2010).

B) We look at, and even if the plaintiffs were unable to know the market price at the time of inheritance of the right to sell the sale in this case, it is merely merely the situation of the plaintiff that the lack of information to evaluate the value of inherited property, and such circumstance alone alone is insufficient to deem that there is a justifiable reason that the plaintiffs are not negligent in neglecting their duty to pay.

3) Sub-decisions

Therefore, the instant disposition is lawful.

3. Conclusion

Then, the plaintiffs' claims are dismissed for lack of reason.