1. Revocation of the first instance judgment.

2. All plaintiffs' claims are dismissed.

3. Total costs of litigation are assessed against the Plaintiffs.

1. This part of the judgment of the court of first instance is identical to the corresponding part of the judgment of the court of first instance, except for adding “(including serial numbers, and unless otherwise specified; hereinafter the same shall apply)” following the fourth 10 of the judgment of the court of first instance, and thus, this part of the judgment is acceptable as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. This part of the relevant statutes is identical to the entry of the relevant statutes in the judgment of the court of first instance. Therefore, this part of the judgment is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

3. Determination on the lawfulness of the disposition imposing inheritance tax of this case

A. The part related to the appraisal of the instant shares 1) Plaintiffs (A) (1) G succeeded to the rights and obligations between H and its members pursuant to Article 27 of the Installation and Utilization of Sports Facilities Act (hereinafter “Sports Facilities Act”). As such, H and G succeeded to the rights and obligations between H and its members, the obligation to return the membership fee that H and G bears to the members of the Sports Center (hereinafter “the obligation to return the instant membership fee”) is the final obligation of G.

(2) Of the total amount of KRW 37,342,224,00 among the members of the instant sports center, KRW 19,791,378,720 (=37,342,224,00 x 0.53) equivalent to 53% of the rate related to the use of the instant sports center should be reflected in the share assessment as G’s liabilities.

(3) Even if the unpaid annual fees and late fees, etc. are deducted from 19,791,378,720 won in relation to the use of the instant sports center, the obligation to return the membership fees to be borne by G is KRW 17,788,796,772.

Furthermore, as of the commencement date of inheritance, the standard amount of the obligation to return membership fees, the net asset value of G does not exceed KRW 0,240,771,238, is merely about 40% of the above obligation to return membership fees. The result of a civil lawsuit in which members sought the return of membership fees from G (hereinafter “relevant civil lawsuit”) and the details of the membership fees entered in the membership list of the sports center of this case.