1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. On August 17, 2016, E of the disposition (hereinafter “the decedent”) died.

As co-inheritors of the inheritee, there are spouse D, the Plaintiff, B, and C.

(hereinafter referred to as “heirs”). On February 28, 2017, the inheritors filed a return with the Defendant on the inheritance deduction amounting to KRW 5,786,69,96,988, and KRW 1,292,292,749, including principal KRW 680,00,000, and interest KRW 612,292,749, and KRW 612,299,749 (hereinafter referred to as “instant disputed obligation”), with the inheritance deduction amounting to KRW 3,057,292,749, and the inheritance tax amounting to KRW 2,729,404,239, the inheritance tax amounting to KRW 293,550,115.

From August 2, 2017 to October 24, 2017, the director of the Central Regional Tax Office determined that the decedent did not prove that he/she actually bears the obligation of this case against the Plaintiff at the time of commencing the inheritance and notified the Defendant of the fact.

Accordingly, on January 5, 2018, the Defendant issued an additional decision on KRW 517,902,050 of inheritance tax to the heir, including the Plaintiff (hereinafter “instant disposition”).

On March 27, 2018, the Plaintiff filed an appeal seeking the revocation of the instant disposition with the Tax Tribunal, but was dismissed on October 5, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) As at the time of commencement of the inheritance, the Defendant actually assumed the instant obligation against the Plaintiff, the said obligation should be deducted from the value of the inherited property. On the other hand, the instant disposition, which did not deduct the instant obligation from the value of inherited property, is unlawful, and thus, should be revoked. 2) The Plaintiff, the Plaintiff, and the B, as a security for the obligation to loans to G organizations (hereinafter “G organizations”) of the F Co., Ltd. (hereinafter “F”) (hereinafter “P”) (hereinafter “loan obligation”).