1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. B died on May 17, 2008, and the Plaintiff is one of its successors.

B. B, on December 11, 2006, filed a preliminary return on KRW 374,182,271 of the transfer income tax reverted to the Defendant on December 18, 2006, along with a sales contract to transfer the Gyeonggi-do Kimpo-si E and F (hereinafter “instant land”) to KRW 1,747,90,000,00.

C. After the death of B, the inheritor did not report inheritance tax, the Defendant conducted an inheritance tax investigation, and the Defendant: “The fact was transferred to G (the husband of the above C) on June 21, 2005, and to D in KRW 1,746,50,000,” and the instant land was deemed not to fall under the disposal property within two years before the inheritance date of the inheritee ( May 17, 2008), and thus, the inheritance tax was imposed on the inheritor.

After that, the Defendant: (a) deemed that “B transferred the instant land to C and D on December 11, 2006, as described in the foregoing Paragraph (b) above, to C and D on December 11, 2006; and (b) deemed that the instant land constituted a disposal asset within two years before the date of commencing the inheritance by the decedent; and (b) increased inheritance tax by the inheritor on July 11, 201.

E. Accordingly, on May 30, 2012, the inheritors filed a lawsuit seeking revocation of the inheritance tax as Seoul Administrative Court No. 2012Guhap17377, and filed a corresponding real estate sales contract, claiming that “The facts were transferred to B at KRW 2,120,750,000 on June 21, 2005,” and the court accepted this on June 21, 2013, and rendered a judgment revoking the imposition of the inheritance tax on deeming that the instant land does not constitute a disposal asset within two years before the date the inheritance commences, and became final and conclusive at that time.

F. According to the above judgment, the Defendant considers B as evading the transfer income tax for the year 2005 by fraud or other unlawful acts, and imposed the transfer income tax for the year 2005 on August 13, 2013 on the inheritor 627,757,030 of the inheritee’s transfer income tax for the year 2005, and then imposed on the inheritor.