All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1. The lower court rejected the Plaintiffs’ assertion that the instant land should be regarded as inherited property on the ground that it was insufficient to recognize that the sales contract for the instant land was concluded prior to May 20, 2005, the date of the deceased’s death on May 20, 2005, by November 21, 2005, the Plaintiff, the heir of the deceased, was included in inherited property except for the instant land, upon filing an inheritance tax report on November 16, 2005.

In light of the records, the above fact-finding and judgment by the court below cannot be said to have violated logical and empirical rules and the principle of free evaluation of evidence.

2.(a)

Article 60(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 7580, Jul. 13, 2005; hereinafter “former Inheritance Tax Act”) provides that the evaluation of inherited property shall be based on the “market price”. Article 60(2) of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (amended by Presidential Decree No. 18903, Jun. 30, 2005) provides that the transaction example related to the pertinent property shall be included in the “market price”.

한편 구 상증세법 제60조 제3항은 상속재산의 시가를 산정하기 어려운 경우에는 당해 재산의 종류규모거래상황 등을 감안하여 제61조 내지 제65조에 규정된 방법에 의하여 평가한 가액에 의하도록 규정하고 있다.

The term "market price" referred to in these provisions shall be free between many and unspecified persons.