1.The judgment of the first instance shall be modified as follows:

Of the instant lawsuit, the Defendant limited to the Plaintiffs on April 8, 2009.

1. Details of disposition;

A. On September 2, 1943, the deceased E (Death of April 30, 2007) married with F on September 2, 1943, 4 South and North Korea as his/her child, namely, G (ma), H (ma), H (2), I (ma), RJ (3), K (4), and L (2).

B. Plaintiff A is the deceased’s spouse of the deceased E’s 3 South Net (Death on September 8, 1996). Plaintiff B, C, and D are the children of the deceased J, and both Plaintiffs are the successors of the deceased E.

C. On October 29, 2007, the deceased E’s successors, including the plaintiffs, reported the taxable value of the deceased E’s inheritance as KRW 7,683,489,061, but on December 14, 2007, they reported to be KRW 7,756,291,289 on December 14, 2007. As for each real estate listed in the separate sheet of real estate Nos. 1 (hereinafter “instant real estate”), the deceased J, the plaintiffs, and the network E’s shares were included in the inherited property as at the time the inheritance commences.

On September 1, 2008, the Defendant imposed on the Plaintiffs KRW 1,774,050,430 of inheritance tax and penalty tax of KRW 162,857,830 in total, and penalty tax of KRW 1,936,908,260 of inheritance tax not reported and paid by the deceased E’s inheritors.

(hereinafter “instant disposition”) E.

After that, the director of the Seoul Regional Tax Office determined the shares of H, I, K, and L (hereinafter referred to as “Isk’s heir”) among the real estate of this case as the property trusted in trust by the network E, and added the amount equivalent to the shares of the other inheritors to the inherited property value. The amount equivalent to the shares of the real estate of this case shall be reduced from 1,551,258,258 to 50,000,000 won in the original amount, and the amount of the spouse deduction shall be reduced from 1,551,258,258 to 12,892,496,025 to increase and decrease the amount of the return of inherited property, the amount of the

F. Accordingly, on April 8, 2009, the Defendant increased the inheritance tax to KRW 4,867,085,925, and increased the penalty tax to KRW 462,382,82,823 (hereinafter “instant adjustment disposition”), and imposed penalty tax to the Plaintiffs for failure to report.

After that, the defendant has been unaware of the payment on June 1, 2009.