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

The grounds of appeal are examined.

1. As to the grounds of appeal on whether “property contributed for public interest” constitutes “property contributed for public interest”

A. Article 16(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9916, Jan. 1, 2010; hereinafter “Inheritance Tax Act”) provides that, among inherited property, where an ancestor or his/her heir has contributed property to a person engaged in a business for religious, academic, academic, or other public interest (hereinafter “public interest corporation, etc.”) within the deadline for filing the inheritance tax base under Article 67 of the Inheritance Tax and Gift Tax Act (where a public interest corporation, etc. is established by contributing the inherited property, referring to six months from the last day of the month to which the date on which such cause ceases to exist, in extenuating circumstances exist), such contribution shall not be included

In addition, Article 13 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 22042, Feb. 18, 2010; hereinafter “Enforcement Decree of the Inheritance Tax and Gift Tax Act”) stipulating the method of contribution, etc. to contributed property to a public corporation upon delegation of Article 16(4) of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 22042, Feb. 18, 2010; hereinafter “Enforcement Decree of the Inheritance Tax and Gift Tax Act”) provides that in cases where the transfer of ownership of donated property is delayed due to statutory or administrative reasons, where the establishment of a public corporation, etc. is delayed due to the contribution of inherited property (Article 16(1)1) and the permission, etc

Meanwhile, Article 17(1) of the Inheritance and Gift Tax Act provides that the value of inherited property shall not be included in the taxable value of inherited property in cases of property contributed to a public corporation, etc. through a trust for the purpose of religious, academic, academic or other public interest (hereinafter “public trust”) among inherited property, which is a public trust under Article 65 of the Trust Act.