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. The reasoning of the judgment of the court of first instance, such as admitting the judgment, is the same as the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as follows 2. Thus, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article

2. The supplementary and additional Plaintiff asserts that, at the time of the first agreement, there was no installment agreement on the instant land share at the time of the first agreement, and around 1999, when selling the instant land share, the Plaintiff, E, D, and C (hereinafter “he co-inheritors”) agreed to have the sales price divided by 1/4. Accordingly, the Plaintiff received KRW 380 million from D, and thus, it does not constitute a gift.

However, the following facts and circumstances, which may be acknowledged by the facts and circumstances acknowledged by the first instance court cited by this court, and by the overall purport of pleadings, are the following facts and circumstances, i.e., the inheritance by consultation and division as of Aug. 30, 1993 as of July 15, 1993, the registration of transfer of ownership in the name of D was completed, and the registration of inheritance in the name of co-inheritors was not completed, and the first agreement dated Mar. 14, 1994 as of the share in the land of this case.

In full view of the following facts: (a) the Plaintiff did not state any content of adjustment; (b) the Plaintiff did not submit any evidentiary document regarding the second agreement around 1999; (c) the Plaintiff did not object to a disposition imposing gift tax on KRW 380 million received from DoD among co-inheritors; and (d) did not dispute such disposition; and (c) the Plaintiff received KRW 380 million from D from 13 years from the date of inheritance; and (d) the time when the registration of inheritance was completed by consultation and division in the name of D with respect to the instant land portion, seven years after the date of inheritance.