1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. On January 15, 2010, the Plaintiffs filed a return on the tax base of inheritance as KRW 4,742,267,876 on the taxable value of inherited property as the heir of D (the decedent’s death on April 17, 2009, and the decedent’s death). The head of the Sungdong District Tax Office conducted an inheritance tax investigation from November 19, 201 to February 14, 201, determined and notified the Plaintiffs of KRW 1,459,157,682 of inheritance tax on March 10, 201.

From December 23, 2013 to July 29, 2014, the director of the Seoul Regional Tax Office conducted an investigation into the source of funds and inheritance tax (hereinafter “instant tax investigation”) with respect to the Plaintiffs, and notified the Defendants. The Defendants considered the portion of the deposited property in the Plaintiffs’ name, the source of funds is unclear (hereinafter “instant deposit”), as a prior donation, and determined and notified the Plaintiffs as gift tax and inheritance tax (including additional tax) as indicated in the attached Table “post notification” column.

(hereinafter referred to as “instant disposition.” The amount of tax determined and notified by the Defendants to the Plaintiffs was reduced later as indicated in the separate sheet “after correction” as indicated in the separate sheet). [Grounds for recognition] There is no dispute, and the entries in Gap’s 1, 2, Eul’s 1 through 6 (including the serial number; hereinafter the same shall apply), and the purport of the entire pleadings.

2. Whether the instant disposition is lawful

A. Article 81-4(2)1 of the former Framework Act on National Taxes (amended by Act No. 12162, Jan. 1, 2014; hereinafter the same) provides that “where a reinvestigation is exceptionally permitted, there is clear evidence to prove the suspicion of tax evasion” as one of the cases where a reinvestigation is exceptionally permitted. This refers to cases where a considerable probability of the fact of tax evasion is recognized based on materials supporting objectivity and rationality.

In addition to the written evidence Nos. 1 and 7, considering the overall purport of the pleadings, E, another child of the inheritee, filed a lawsuit against the Plaintiffs, the Seoul Family Court No. 2009Ra153.