1. Of the disposition imposing inheritance tax of KRW 540,781,690 (including additional tax), which the Defendant imposed on the Plaintiffs on November 1, 2013, 529,356.

1. Details of the disposition;

A. C concluded four non-dividend IBK Pension Policy (hereinafter “instant insurance contract”) with the beneficiary as the Plaintiffs at the time of the insured and death as indicated below, and paid 2,040,000,000 won in total of the premium.

C C C A AB

B. (1) On June 18, 2012, C died, and the Plaintiffs, who are spouse D and children, inherited C’s property.

(2) The Plaintiffs: (a) assessed the value of inherited property as KRW 1,466,223,468; and (b) reported the amount of inherited property in combination with other inherited property as KRW 21,501,156,683, the value of inherited property was KRW 4,366,048,218,218, on the ground that “The right under the instant insurance contract constitutes the right to receive a regular payment” under Article 65(1) of the Inheritance Tax and Gift Tax Act (hereinafter “Inheritance Tax Act”) and Article 62 of the Enforcement Decree of the said Act.

C. On November 1, 2013, the Defendant assessed the value of inherited property as KRW 2,040,000 on the ground that “The insurance premium paid by C has been inherited prior to the commencement of the payment of periodic payments,” and assessed the value of inherited property as KRW 21,597,248,667 in combination with other inherited property at KRW 21,597,248,667,829, and then additionally assessed the value of inherited property as KRW 540,781,69 (including additional taxes).

The Plaintiff appealed and filed an appeal on January 28, 2014, but was dismissed by the Tax Tribunal on April 14, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2 (including additional number), Eul evidence 1, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiffs' assertion that the contract of insurance takes effect upon the conclusion of the contract, and the claim for insurance is specified only when the insurance accident occurs, and the insurance contract of this case is an insurance for which the fixed-term fund is paid.