1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On July 11, 2008, the Plaintiff reported and paid KRW 36,820,840 of the inheritance tax calculated by applying the taxable amount of inheritance tax to KRW 1,779,209,380 on January 6, 2009, as the Plaintiff attached B (hereinafter “the decedent”) died.

B. The Defendant (at the time, the head of Song District Tax Office was the head of Song District Tax Office due to the division due to the reorganization) conducted an inheritance tax investigation, and as a result, the Plaintiff, C, and D deemed the land and above ground buildings owned 1/3 of their respective shares as the trust property in the name of the inheritee (hereinafter “instant real estate”) and imposed inheritance tax of KRW 1,69,377,990 on October 1, 201, including the inherited property, on October 1, 2010.

C. On December 23, 2010, the Plaintiff dissatisfied with the foregoing, filed an objection with the director of the Seoul Regional Tax Office on the purport that the instant real estate is not a title trust, but a prior donation property. The Plaintiff filed an objection with the director of the Seoul Regional Tax Office having to recognize the obligation to refund the deposit deposit amount of KRW 55,00,00 (hereinafter “the obligation to refund the deposit deposit of this case”) with respect to the instant real estate as the obligation of the inheritee. On May 12, 2011, the Seoul Regional Tax Office determined that the instant real estate shall be added to the inherited property under the name of the inheritee, but shall be assessed as the sum of the inherited property in the name of the inheritee, and shall be assessed as the amount that was actually borne at the time of acquisition with the amount that was assessed as the amount that was deducted from the taxable amount of inheritance tax as the obligation to return the deposit deposit of this case, and the Defendant calculated the taxable amount of inheritance tax by deducting the obligation to return the deposit deposit of this case as the amount of inheritance tax.

On August 18, 2011, the Plaintiff filed an appeal with the Tax Tribunal to the effect that the instant real estate is not a trust property under the name of the inheritee, but a prior donated property. The Tax Tribunal on March 20, 2012 should be deemed as a prior donated property.