A. On September 3, 2007, the Plaintiff and B acquired housing located in Singapore (C; hereinafter “instant housing”) from USD 2,660,814.79 of Singapore (SGD; hereinafter “US”) and transferred the housing to USD 2,660,814.79 (The Plaintiff’s shares: 2/3, B: 1/3) on May 29, 201.

B. At the time of the acquisition of the instant housing, the Plaintiff and B obtained a loan of USD 1,806,000 from the financial company located in Singapore (OCBC Bank) to the parent-base loan, and used it as the acquisition fund. Since then, at the time of the transfer of the instant housing, USD 1,690,957.38,000, excluding USD 115,806,000, which was already repaid at the time of the transfer of the instant housing, was repaid first to the above OCB Bank.

C. Meanwhile, with respect to the transfer of the instant house, the Plaintiff caused the transfer loss of USD 4,724.79 [$ 2,700,000 for transfer value + USD 1,690,957.38- for base loan – USD 43,910 for transfer cost] ($ 2,660,814.79- for 1,806,000 for 1,806,00 for 115,042.62) and did not report the transfer income tax, etc. to the Defendant in relation to the transfer of the instant house.

However, on April 7, 2014, the Defendant deemed that the acquisition value and transfer value of the instant housing, including bank loans, were converted by applying the basic exchange rate at the time of acquisition and transfer, and notified the Plaintiff of the correction and notification of the transfer income tax of KRW 217,228,170 (including additional tax) for the transfer income tax of April 7, 201.

(hereinafter referred to as “instant disposition”). (e)

On September 16, 2014, the Plaintiff filed an objection and filed an appeal with the Tax Tribunal on September 16, 2014, but was dismissed on December 1, 2014.

[Ground of recognition] Facts without dispute, Gap 1-8 evidence, Eul 1-1 evidence (including paper numbers), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. (1) The Plaintiff’s assertion that the Plaintiff borrowed part of the acquisition amount from a local financial company when acquiring the instant house, and paid the said loan to the local financial company immediately when transferring it.