A. On October 1, 2002, the Plaintiff purchased a building of 326.9 square meters (hereinafter “instant land”) and the 2nd floor thereof, and completed the registration of ownership transfer, and removed the above building on the beginning of 2004, and newly constructed a multi-family house of reinforced concrete mentor structure (hereinafter “instant building”) and a multi-family house of reinforced concrete mentor structure (hereinafter “multi-family house of this case” with the instant land, and completed the registration of ownership transfer on June 30, 2004 after obtaining approval for use on June 24, 2004.

B. At the time of approval for use, the current status on the registry of the instant building was 125.9 square meters on the ground-based residential facilities (retail stores) 125.9 square meters on the ground-based 1st, 69.42 square meters on the parking lot, 2nd class neighborhood living facilities (office) 191.07 square meters on the second class neighborhood living facilities (office) on the second class 3 floor, 191.07 square meters on the ground-based 191.07 square meters on the second class neighborhood living facilities (office) on the third class neighborhood living facilities (office), 180.93 square meters on the ground-based 4th class multi-family house (three households) and 24.17 square meters on the rooftop floor, but the Plaintiff changed the use of 174.09 square meters on March 30, 20

C. After doing so, the Plaintiff sold the instant real estate in KRW 3.1 billion to D, and completed the registration of ownership transfer on February 28, 2014, but concluded a delegation contract with the Defendant, who is a certified tax accountant on April 2014, and paid remuneration of KRW 3 million on April 28, 2014.

On April 30, 2014, the Defendant, on behalf of the Plaintiff, submitted a return of tax base of transfer income and a statement of calculation of transfer income, etc. on behalf of the Plaintiff, and filed a return of tax base of transfer income with the tax base attached thereto, which deducts KRW 808,007,228 of the special long-term holding deduction rate of 80% from the special long-term holding deduction rate of KRW 1,010,009,036 based on high-priced houses which are one house per household.

E. As of February 28, 2014, the Defendant calculated by adding up the period of possession before and after new construction as of February 28, 2014, the date of the said report (except for a period of about four months for new construction) by the Plaintiff.