The judgment below is reversed and the case is remanded to Seoul High Court.

The grounds of appeal are examined.

1. Regarding ground of appeal No. 1

A. The main text of Article 3(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “Inheritance Tax Act”) provides that “he heir is liable to pay inheritance tax according to the ratio calculated as prescribed by the Presidential Decree based on the property that he/she received or is to receive, among inherited property.” Article 3(4) provides that “The inheritance tax pursuant to the provisions of paragraph (1) shall be jointly and severally liable to pay inheritance tax within the scope of the property that he/she received

B. The lower court found the following facts: (a) although B died on April 5, 2009, six co-inheritors, including the Plaintiff, etc., who were co-inheritors, did not report inheritance tax; (b) on July 6, 201, the Defendant served the Plaintiff on July 6, 201 on the aggregate of the value of inherited property; and (c) on the list of inheritance tax and co-inheritors liable for joint and several payment (hereinafter “list of co-inheritors”), the Defendant served on the Plaintiff on July 6, 2011 the total amount of inherited property; (d) together with the total tax amount of KRW 1,030,404,760, one of the six co-inheritors. The lower court stated the phrase “one of the six co-inheritors, including the Plaintiff, at the time of payment for one of the entire co-inheritors.” (e) on the list of co-inheritors, stating the name, resident registration number, relationship with the inheritee, inheritance ratio, inheritance ratio, and tax amount to be paid by the Plaintiff.

Furthermore, the lower court: (a) stated the total amount of tax to be paid by the Defendant in the notice of tax payment by six co-inheritors, including the Plaintiff, notified the collection of the total amount of tax jointly and severally liable by six co-inheritors; and (b) considered that the amount of tax to be paid by each of the above co-inheritors was individually imposed and notified by the list of co-inheritors; and (c) if other co