1. Of the judgment of the court of first instance, the part against the defendant is revoked, and all the plaintiffs' lawsuits constituting the revoked part are revoked.

1. The reasons why the court should explain this part of the disposition are the same as the corresponding part of the judgment of the first instance, except where the 6th instance judgment under the 3th sentence of the judgment of the first instance states "A" as "A". Thus, this part of the judgment is cited in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the part of the lawsuit in this case, which was revoked ex officio, is lawful, and if an administrative disposition is revoked within the scope of adjudication of this court, the disposition becomes null and void, and no longer exists, and a revocation lawsuit against a non-existent administrative disposition is unlawful as there is no benefit of lawsuit.

(see, e.g., Supreme Court Decision 2012Du18202, Dec. 13, 2012). The Defendant rendered a decision to revoke ex officio the reduction of the amount exceeding KRW 542,537,058 out of the additional tax on negligent tax returns on September 15, 2017 (Evidence A13), among the instant disposition, exceeding KRW 575,947,123, the amount of KRW 542,537,058, among the instant disposition. As such, the instant lawsuit on the part revoked ex officio (the part against the Defendant in the judgment of the first instance) among the instant lawsuit

On the other hand, the first instance court dismissed all the remaining claims except for the part against the above defendant among the plaintiffs' claims seeking revocation of the disposition of this case. The plaintiffs filed an appeal against the judgment of the first instance only on the part of additional tax of KRW 625,420,097 (additional tax of KRW 82,883,039, and additional tax of additional tax of KRW 542,537,058). The scope of the judgment of this court is limited to the above additional tax.

3. The Plaintiffs’ assertion 1) The instant account was managed in the Plaintiff’s name for 27 years. Accordingly, the instant financial property was wholly amended by the former Inheritance Tax Act (wholly amended by Act No. 5193, Dec. 30, 1996; hereinafter the same applies).

(1) Article 34(1) of the Inheritance Tax and Gift Tax Act (hereinafter “Gift Tax Act”) shall be deemed to have been donated to Plaintiff C pursuant to the provision regarding donation, such as transfer of property to a lineal ascendant or descendant, or deemed to have been donated to Plaintiff C.

(b).