1. The plaintiff (appointed)'s claim is dismissed.

2. The costs of lawsuit shall be borne by the plaintiff (appointed party).

1. Facts of recognition;

A. On September 21, 2010, the Plaintiffs’ attached and the decedent B (hereinafter “the deceased”) died. On March 31, 2011, the Plaintiffs assessed the value of each of the instant lands to the head of Seongbuk-gu, Seongbuk-gu, and reported the value of inherited property to KRW 6,458,342,00, by evaluating the value of each of the instant lands to the head of Seongbuk-gu, Seongbuk-gu, and eight parcels (hereinafter “each of the instant lands”). On February 1, 2012, the head of Seongbuk-gu Tax Office determined the value of inherited property as KRW 6,546,919,135, including any property omitted, such as prior donation property, etc., and imposed inheritance tax of KRW 2,096,861,067 on the Plaintiffs.

(B) Prior to the above disposition, the inheritance tax imposed upon the plaintiffs by voluntarily paying KRW 200 million is KRW 2,296,861,067.

However, in the process of selling each of the instant lands by entrustment to the Korea Asset Management Corporation, the appraisal corporation assessed the value of each of the instant lands in total at KRW 5,560,598,000. On July 9, 2015, the Plaintiffs filed a claim for correction of inheritance tax with the head of Seongbuk-gu Tax Office for correction of inheritance tax amounting to KRW 2,069,614,067, based on the market price of each of the instant lands, not the publicly assessed individual land price, and the inheritance tax amount was changed to KRW 2,069,614,067. However, the Plaintiff was notified of the rejection of the request for correction

C. The Plaintiffs appealed and filed an appeal with the Tax Tribunal, and the Tax Tribunal dismissed the Plaintiffs’ claim on April 12, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 6 and Eul evidence 1 to 4 and 6 (including each number), the purport of the whole pleadings

2. The assertion and judgment

A. The plaintiff's assertion asserts that the public official belonging to the defendant did an illegal act that imposed the inheritance tax calculated at a higher level on the basis of the officially assessed individual land price without going through the appraisal procedure for each land of this case, as shown in the attached Form, against the defendant.