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

The Defendant’s disposition of imposition of KRW 168,282,960 (including additional tax) of inheritance tax against the Plaintiffs on November 17, 2016 shall be revoked.

2. Purport of appeal

The judgment of the first instance is revoked. All of the plaintiffs' claims are dismissed.

This court's reasoning is the same as the reasons for the judgment of the court of first instance except for the supplement or addition of the judgment as follows 2, and it is also cited in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Supplement and addition of judgments;

The Defendant asserts that since ○○○ and △△○ from 1984 to 2003, the deceased operated a private business entity, including the deceased, and filed a comprehensive income tax with the National Tax Service, it cannot be readily concluded that the deceased did not have the ability to acquire the instant land. Since there is no specific evidence or proof that the Plaintiff ○○ paid the acquisition price of the instant land, it is against the presumption of real estate registration that the actual owner of the instant land is recognized as Plaintiff

In full view of the following facts and circumstances acknowledged by the purport of entry of evidence Nos. 9, 19 through 32, 35, 36, 37, and 40 and the purport of the entire pleadings, it is reasonable to view that the source of the funds to acquire the instant land was Plaintiff ○○ who was engaged in various businesses at the time of the acquisition of the instant land, and Plaintiff ○○○ was directly engaged in the development and profit-making activities after the acquisition of the instant land, and that the instant land was controlled and managed as the actual owner of the instant land. The Defendant’s assertion on other premise is without merit.

In 1968, Plaintiff ○○ had participated in the Vietnam War as a American literature, and had returned to Korea and had engaged in managing the PX store in the U.S. military. Since that time, Plaintiff ○ began to handle precious metals, and the U.S. military began to provide gold banks to ○○ as the US military transferred to ○○.

○ ○○○ and ○○ Gas station from 1974 to 1979 as a partnership business.

It was operated by ○○○○○○-dong underground shopping mall, and it was also engaged in sales of local products at ○○○-dong underground shopping mall (○○○-dong).

○ Also, the name of the deceased at the ○○○○-dong ○○○○○○○○ around 1980 around 198.

The sales business of precious metal was opened ○○○, the acquisition and operation of the ○○ Sound System, and the sales business of new locks, ginseng, etc. was conducted, and since 1984, the sales business of precious metal was conducted from ○○ underground to △○ to △△ in the trade name of △△.

Around September 1986, Plaintiff ○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○○, which borrowed the deceased’s name, concurrently operated the term “○○○○○○○○” store and the phrase “○○○○○○○○” in the name of the deceased.

○ The Plaintiff ○○ borrowed the name of the deceased as above and reported business registration and taxes.

The purpose was to prevent taxes from being excessive according to the progressive tax rate in the case of a new business in the name of the plaintiff chi○○ who had already operated another business.

○ Deceased did not engage in income activities as a professional supervisor.

3. Conclusion

If so, the plaintiffs' claims are justified. The judgment of the first instance court with the same conclusion is just, and the defendant's appeal against the plaintiffs is without merit, and all of them are dismissed.