1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

Judgment of the first instance.

1. The reasons for the court’s explanation concerning this case are as follows: (a) the dismissal or addition of part of the judgment of the court of first instance as referred to in paragraph (2); and (b) the addition of the judgment of the plaintiff’s new or new argument to the court of first instance as referred to in paragraph (3) is the same as the entry of the reasons for the judgment of the court of first instance; and (c) thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act

(hereinafter the meaning of the terms used in this subparagraph is the same as that of the judgment of the first instance court). 2. The second part of the term "the plaintiff" in the second part is added to "the plaintiff" as "the inheritor".

Part II, under the second Schedule, " September 11, 2013" shall be " September 2, 2013".

The third party "249,646,879 won" shall be deemed "249,464,879 won".

The phrase “A No. 7” shall be added to the 3rd 5-6 conduct (based on recognition).

The "this Court" in the second sentence shall be deemed to be the "Court of First Instance".

The second sentence " October 10, 2017" in the second sentence shall be construed as " January 10, 2017".

3. Additional determination

A. The Plaintiff’s assertion that the instant insurance contract has the nature of life insurance, and it is unlawful to calculate the value of donated property on the basis of a much larger termination refund than that of the Plaintiff, as the insurance amount that the Plaintiff could have received when assumed that B died within the first insurance period.

B. According to Article 60(1) of the Inheritance and Gift Tax Act, the evaluation of the value of donated property should be based on the date of donation, and the fact that the Plaintiff transferred the status of the contractor and beneficiary of the insurance contract of this case on October 31, 2008 is as seen earlier. As of October 31, 2008, B was not dead, and there was no limitation on the Plaintiff’s exercise of the right of termination by exercising the right of termination at will to receive the refund for termination. Therefore, the amount that corresponds to the property value of the policyholder and beneficiary of the insurance contract of this case donated by the Plaintiff is the most appropriate amount.