1. The plaintiffs' appeal is dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. The plaintiff A is the wife of the deceased E (hereinafter "the deceased"), who died on May 20, 2005, and the rest of the plaintiffs are the children of the deceased.

B. On November 16, 2005, the Plaintiffs reported KRW 15,304,282,960 as inheritance tax payable pursuant to Article 67(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 7580, Jul. 13, 2005; hereinafter “the Inheritance Tax Act”) and Article 64 of the Enforcement Decree of the same Act (amended by Presidential Decree No. 18903, Jun. 30, 2005; hereinafter the same) as co-inheritors of the deceased, and voluntarily paid KRW 3,826,070,740 as inheritance tax, and obtained approval for annual payment of KRW 11,478,212,20 as inheritance tax.

C. On the other hand, on July 5, 2007, the Defendant imposed an inheritance tax (including additional tax; hereinafter referred to as “previous disposition”) on the Plaintiff A, as follows: ① KRW 314,413,80 on the following grounds: ② KRW 1,482,513,010 on the Plaintiff B; ③ KRW 2,324,601,020 on the Plaintiff C; ④ KRW 2,321,379,670 on the Plaintiff D, respectively.

1. It is reasonable to assess the sale price as KRW 10,303,349,998, which is the officially announced value at the time of the commencement of inheritance by the Plaintiffs at the time of the commencement of inheritance tax return, on the land of Suwon-si F and ten parcels (hereinafter collectively referred to as “instant land”).

2. The portion exceeding KRW 1,339,880,142 according to the final and conclusive judgment between the Deceased and Quasi-Appellant Construction among the obligation for construction payment for quasi-Appellant Construction Co., Ltd. (hereinafter “Quasi-Construction”) reported as KRW 2,501,865,980 upon the filing of inheritance tax by the Plaintiffs should be denied. Of the obligation for G reported as KRW 388,356,164, the portion exceeding KRW 180,356,164 due to the judicial adjustment between the Deceased and G should be denied.

3. It shall be assessed as 6,170,976 won and assessed as 6,170,976 won and added to inherited property by the Plaintiffs at the time of their return of inheritance tax.

4...