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

A. The Plaintiff’s father B (hereinafter “the deceased”) died on October 23, 2014, and his heir had C, Plaintiff, D, E, F, etc., the wife of the deceased.

B. Meanwhile, upon the implementation of the G City Redevelopment Project, the Deceased was replaced by 1,321mm2 (hereinafter “instant land before the instant land substitution”) with I,357m2 (hereinafter “the instant land after the instant land substitution”) located in the G City Water Zone, which was owned by him/her based on a disposition of replotting on December 3, 2010 (hereinafter “instant disposition of replotting”).

다. C은 2015. 4. 30. 피고에게, 이 사건 환지 후 토지를 상속재산에 산입하고 그 가액을 1㎡당 2,044,245원으로 보아 계산한 730,000,000원(≒ 2,044,245원 × 357.1㎡)을 위 토지의 가액으로 하고, 망인이 사용처를 소명하지 못한 부동산 양도대금과 임대보증금 합계 242,000,000원을 상속개시 전 처분재산액에 산입하고, 상속세 과세가액에서 공제되는 채무를 2,175,952,587원으로 산정한 후, 상속세 과세표준을 1,472,745,031원, 납부할 세액을 386,188,211원으로 하여 상속세 신고(이하 ‘이 사건 상속세 신고’라 한다)를 하였다

(No. 1.D.)

However, the deceased’s inheritors did not pay the inheritance tax reported as above. On July 8, 2016, the Defendant decided and notified the deceased’s inheritors including the Plaintiff, etc. of KRW 386,188,211 and KRW 35,336,221 in total, KRW 421,524,432.

(B) No. 2, hereinafter referred to as “the first disposition”). (e)

On the other hand, on July 22, 2016, F of the deceased’s heir F filed a claim for correction on the ground that on the ground that on the inherited property, the deceased owned only 1/3 of his/her share in the Gyeonggi-gu J Forest, Gyeonggi-do, and that he/she had owned only 49,587 square meters, he/she had over- assessed the taxable value of inherited property. On August 25, 2016, the Defendant reduced or corrected KRW 26,743,57 out of the total amount of tax notified

F. After that, the Plaintiff was to the National Tax Service on September 22, 2016.