A. On January 7, 1994, the deceased D (hereinafter “the decedent”) established a corporate E (E) corporation for the purpose of manufacturing and selling kitchen supplies (hereinafter “E”) and took office as the representative director on the same day, and died on July 30, 2014 while managing E as a family business for about 20 years.

B. As a result of the death of the decedent, Plaintiff A and C, who are the spouse of the decedent, were inherited by inheritance of 62,100 shares of E owned by the decedent.

On December 8, 2014, the Plaintiffs assessed the value of the entire inherited property as KRW 49,311,757,434, and the value of KRW 62,100 among them as KRW 45,655,236,90, respectively, and reported and paid inheritance tax calculated by applying the inheritance tax deduction under Article 18(2)1 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”) with respect to shares 62,100.

C. After conducting a tax investigation on the above inherited property, the director of the Seoul Regional Tax Office notified the Defendant that the share (hereinafter “instant share”) of the Vietnam Corporation F (hereinafter “F”) owned by E constitutes “stocks, bonds, and financial instruments possessed without direct connection with corporate business activities” under Article 15(5)2 (e) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 26069, Feb. 3, 2015; hereinafter “former Enforcement Decree of the Inheritance Tax and Gift Tax Act”). The key issue value of the instant share constitutes “stocks, bonds, and financial instruments owned by E” under Article 15(5)2 (e) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act.

Accordingly, on September 2, 2015, the Defendant re-calculated the deductible amount for inheritance of a family business after excluding the shares in the instant case from the total asset value of E, and notified the Plaintiffs of the inheritance tax of KRW 9,401,813,340 (including additional tax of KRW 527,947,562).

(hereinafter “instant disposition”) D.

The Plaintiffs are dissatisfied with the instant disposition and on November 27, 2015.