The defendant's appeal is dismissed.

Expenses for appeal shall be borne by the defendant.

Purport of claim and appeal

purport.

1. The reasoning of the judgment of the court of first instance as to this case is as follows, and the defendant's argument that is added to this court is emphasized by this court is cited in the reasoning of the judgment of the court of first instance, except where the defendant makes an additional decision as set forth in the following three, and thus, it is also cited in accordance with the main sentence of Article 420 of the

2. The actual substance of the judgment of the court of first instance is as follows: (a) Section 2(b) of Section 1-2 of the judgment of the court of first instance.

3. The defendant asserts that the procedure for payment by annual installments is a kind of contract, and therefore, the time when the main content of the contract is determined is the time when the payment by annual installments comes into existence, that is, the time when the permission for payment by annual installments was made. Thus, the interest rate at the time of permission for payment by annual installments should be applied to the entire period of payment by

On the other hand, when the additional dues stipulated in Article 72 of the Inheritance Tax and Gift Tax Act are permitted to pay the annual installments of inheritance tax, the additional dues under the provisions of Article 72 of the Inheritance Tax and Gift Tax Act, Article 69 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act, and Article 43-3 (2) of the Enforcement Decree of the Framework Act on National Taxes naturally occur according to the period of annual installments without the procedure for establishing additional dues of the tax authority, and the amount thereof is determined by agreement between the tax authority and the taxpayer, and it does not mean that the additional dues

Therefore, the first defendant's assertion on a different premise is without merit.

4. Conclusion, the first instance judgment is justifiable, and the defendant's appeal is dismissed.