A. The Plaintiffs are the spouses and children of Nonparty G who died on April 29, 2009 (hereinafter “the deceased”).

B. On October 30, 2009, the Plaintiffs filed a return on the inheritance tax base with the total value of KRW 52,850,000,00 in Yongsan-gu Seoul Special Metropolitan City N,O, and P (hereinafter “P real estate”), which is a road on land category, and voluntarily paid KRW 13,820,000,00 in total, among the inherited property of the deceased.

C. However, unlike the plaintiffs' above details, the defendant, unlike ① the above contents of the plaintiffs' report, refers to the average value of the appraisal value on the written appraisal report prepared by a new appraisal corporation future in the company on October 23, 2007 by the appraisal corporation, which was based on the standard appraisal value prepared on October 22, 2007 (hereinafter "the appraisal value of this case") with respect to the above real estate after consultation by the Deliberation Committee on the Evaluation of Unlisted Stocks of the Central Tax Office (hereinafter "Evaluation Deliberation Committee")

A total of KRW 1,725,275,50, and ② under the management and disposal plan for the urban environment rearrangement project (hereinafter “instant management and disposal plan”), which was approved on March 14, 2008, the redevelopment right on M real estate constitutes “right to acquire real estate” under Article 61 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “former Inheritance Tax Act”). Under the premise that the right to acquire real estate under the above management and disposal plan constitutes “right to acquire real estate”, the value was calculated by subtracting KRW 1,076,882,462, which was calculated by subtracting the value of real estate of KRW 1,725,275,50 from the above appraisal value of KRW 1,725,82,462, and ③ the value of real estate is assessed as KRW 93,342,80 on the ground that it does not actually fall under the road.