1. The plaintiff's claim is dismissed.

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

1. Details of disposition;

A. On December 29, 2003, the Plaintiff registered the transfer of ownership on the ground of inheritance by an agreement and division made on April 26, 2003 with respect to the share of 4/12 (hereinafter “1 real estate”) and the share of 3/12 (hereinafter “2 real estate”) among the neighborhood living facilities on the fourth floor of the ground reinforced concrete structure, which was located in Jung-gu, Busan (hereinafter “the date commencing the inheritance of this case”) and the share of 4/12 (hereinafter “12 real estate”).

B. The Plaintiff on August 26, 2014

The registration of ownership transfer was made on January 8, 2013 with respect to the shares of 1/12 (hereinafter referred to as "third real estate") among the buildings mentioned in the port due to legacy.

C. On October 31, 2018, the Plaintiff sold 1 through 3 real estate to D Co., Ltd. in KRW 2,066,666,67. The Plaintiff reported and paid KRW 337,171,317 of the capital gains tax for the year 2018, which is calculated by adding the acquisition value of each of the said real estate to the standard market price according to the supplementary assessment methods prescribed in Article 61(1) of the Inheritance Tax and Gift Tax Act.

The Plaintiff requested a certified public appraiser to appraise the market price of the first and second real estate.

As a result, according to the appraisal document prepared on February 18, 2019, the market price of the first real estate was 927,92,00 won in terms of the commencement date of the instant inheritance, and the market price of the second real estate was 102,345,60 won in terms of the market price of the second real estate.

(hereinafter referred to as “first appraisal value”) e.

The plaintiff shall regard the appraisal value of the first and second real estate as the market price at the time of the commencement of the inheritance in this case, and shall calculate the acquisition value of the first to third real estate as the acquisition value of the second real estate (the amount calculated by subtracting depreciation costs from the first appraisal value) KRW 62,316,622 (the amount calculated by subtracting depreciation costs from the first appraisal value) by calculating the acquisition value of the third real estate of KRW 32,501,08 (the same amount as the acquisition value reported at the time of the initial return and payment of capital gains tax at the time of the return and payment of capital gains tax as in the previous market price) on the basis of the above calculated the capital gains tax again on April 10, 2019 (the third real estate is calculated as the standard market price as in the previous market price).