All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. The main sentence of Article 97(1)1 (a) of the former Income Tax Act (amended by Act No. 12169, Jan. 1, 2014; hereinafter the same) provides that when calculating gains on transfer of a resident, the acquisition value to be deducted from the transfer value shall, in principle, be calculated based on the actual transaction price incurred in acquiring assets. Article 163(9) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26067, Feb. 3, 2015; hereinafter the same) delegated by Article 97(5) of the former Income Tax Act provides that the assets inherited or donated shall be deemed the actual transaction price at the time of acquisition as of the date of commencing inheritance or donation.

Meanwhile, Article 60 (1) of the Inheritance Tax and Gift Tax Act provides that the value of property on which inheritance tax or gift tax is levied shall be based on the market price as of the date of commencing the inheritance or the date of donation, and Article 61 (3) provides that in cases where it is difficult to calculate the market price, the value assessed by the methods prescribed in Articles 61 through 65 shall be deemed the market price in consideration of the type, size, transaction status, etc. of the relevant property.

In addition, Article 50(6) of the Enforcement Decree of the Inheritance Tax and Gift Tax Act (hereinafter “Enforcement Decree of this case”) provides that “In applying the provisions of Article 61(1)1 of the Act, the officially assessed individual land price shall apply to the publicly notified individual land price as of the base date of appraisal.”

2. Based on its stated reasoning, the lower court completed the registration of ownership transfer with respect to each 1/2 share due to inheritance due to a consultation division held on February 17, 1997 by the Plaintiffs.