1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

The reasons for this judgment of this court is that "Article 97 (1) 1 (a) of the Income Tax Act, Article 163 (9) of the Enforcement Decree of the Income Tax Act" is "Article 97 (1) 1 (a) of the former Income Tax Act (amended by Act No. 15225, Dec. 19, 2017); Article 163 (9) of the Enforcement Decree of the Income Tax Act / [Article 60 (1) of the Inheritance Tax and Gift Tax Act) / [the main sentence of Article 60 (1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 1438, Dec. 20, 2016); Article 60 (1) of the Inheritance Tax and Gift Tax Act (amended by Act No. 14388, Dec. 20, 201); Article 163 (9) of the Enforcement Decree of the Income Tax Act / [the main sentence of Article 80 (2) of the Civil Procedure Act]

In conclusion, the judgment of the first instance court is justifiable, and the plaintiff's appeal is dismissed as there is no ground.