1.The judgment of the first instance shall be modified as follows:

The plaintiffs' preparatory measures against the defendant's Seongbuk Tax Office.

1. The reasons why the court should explain this part of the disposition are as stated in the corresponding part of the judgment of the first instance except for adding "and the head of the Sungbuk District Tax Office imposed an inheritance tax of KRW 2,096,861,060 on the plaintiffs on February 1, 2012." This part of the judgment of the second instance is as stated in Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. The plaintiffs' assertion

A. The head of Seongbuk-gu Tax Office assessed the market price of each land of this case as 6,546,919,135 won based on the officially assessed individual land price, and imposed inheritance tax on the plaintiffs. However, in the course of the public sale of each land by entrusting the Korea Asset Management Corporation with the public sale of each land of this case, the appraisal corporation assessed the appraisal price of this case as approximately KRW 5,560,598,000, which is less than the publicly assessed individual land price. Therefore, in the disposition of the inheritance of this case, the disposition of the inheritance of this case is null and void, since there is a defect that erroneously assessed the market price of each land of this case and the defect is serious and obvious. Accordingly, the disposition of the inheritance tax of this case is also null and void. 2) In addition, since the defendant Seongbuk-do Tax Office could sufficiently know the circumstance that the publicly assessed individual land price of this case was excessively calculated in the process of the public sale of this case, the disposition of the inheritance tax of this case was ex officio corrected or notified to the plaintiffs.

Therefore, the disposition of this case, the disposition of collection, and the disposition of refusal to correct inheritance tax is null and void because there is a serious and apparent defect in violation of the Constitution, Article 81-16 of the Framework Act on National Taxes, Articles 4 and 25 of the Administrative Procedures Act.