2. The defendant.

A. The Plaintiff’s tax claim against B is 1) B, the father of the Defendant, is the father of the Defendant, and B, on September 24, 2012, 3: (a) on September 24, 2012, 826 square meters and 827 square meters before E (hereinafter “1 land”).

(2) On November 2012, 2012, B sold 335,000,000 won to F, and on September 25, 2012, B completed the registration of ownership transfer with respect to the said real estate, sold to F the amount of KRW 45,60,000 (hereinafter “second-party land”) and KRW 2,258,000,000,000, which completed the registration of ownership transfer with respect to the said real estate. < Amended by Act No. 11406, Nov. 20, 2012>

(3) B) On December 18, 2012, 2012, the Korea Rail Network Authority: (a) 53 square meters in the first return to the Korea Rail Network Authority in Busan Metropolitan City (hereinafter “third land”).

B sold 10,38,000 won, and completed the registration of ownership transfer for the above real estate on the same day. B submitted a statement of tax base return and payment for the transfer income tax to the head of Seogu Tax Office from December 2, 2012 to May 2013, 2013, that since land 1, 2, and 3 falls under farmland for eight years, capital gains tax should be reduced or exempted in accordance with Article 66(9) of the Enforcement Decree of the Restriction of Special Taxation Act.

5) On June 1, 2014, the head of the Seogu District Tax Office: (a) did not reside in the location of the land B No. 1, 2, and 3; (b) notified that B denied the said application for reduction and exemption on the ground that B did not do so; and (c) paid capital gains tax of KRW 303,357,210 by June 30, 2014; (b) on May 2, 2018, the sum of capital gains tax and its additional charges to be paid by B to the Plaintiff as of May 2, 2018 (i.e., capital gains tax of KRW 479,910,80 (= capital gains tax of KRW 303,357,210).

B. The Defendant donated to the Defendant in B, as shown in the attached Table 2 No. 1, received KRW 285,00,000, which was part of the remainder of the purchase price of the land No. 1 from the buyer of the land No. 1, from the buyer of the land No. 1, as set forth in the attached Table 2 No. 2, and received from B each of the above money in the manner that B received from the buyer F of the

[Reasons for Recognition] Unsatisfy, Gap evidence Nos. 1 through 5, 8, 10, 11, 13, 14, 16, 17, 19, 22, 23, 26, 33 and 34.