A. As of October 22, 1969, the Plaintiff transferred the instant land to KRW 290,531,280 on June 29, 2009, after completing registration of preservation of ownership with respect to B forest land 5,505 square meters and C forest land 127 square meters (hereinafter collectively referred to as “the instant land”).

B. On May 26, 2010, the Plaintiff filed a transfer income tax on the transfer of the instant land by applying the reduction or exemption for self-farmland for eight years, but the Defendant, following a tax investigation with the Plaintiff, did not accept the application for reduction or exemption of the transfer income tax, deeming that the instant land is not farmland at the time of transfer, and did not accept the application for reduction or exemption of the transfer income tax, and on May 7, 2012, the Plaintiff corrected and notified (including additional tax) the transfer income tax amount of KRW 51,359,950 (hereinafter “instant disposition”).

[Reasons for Recognition] Unsatisfy, Gap 3, 4, and Eul 1

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The result of the current status survey conducted at the time of purchasing the instant land was confirmed as “former”, and it is unreasonable for the Defendant to reject an application for reduction or exemption of capital gains tax on self-Cultivating farmland for not less than eight years, even though the Plaintiff was temporarily closed due to health deterioration. 2) It is unreasonable for the Defendant to impose penalty tax even if there was no notification that the Defendant would have passed one year and six months after the completion of the tax investigation.

(b) as shown in the attached Form of the relevant statutes;

C. On March 6, 1951, the Plaintiff inherited the instant land upon the death of father D on March 6, 1951, and both her mother and her mother reside in E.

Around 24 years of age, 1962, relocated to Seoul.

B) Since then, the Plaintiff cultivated the instant land to F by entrusting F with the cultivation of the instant land. Since 1980, the Plaintiff entrusted F with the cultivation of the instant land to G, who is a f’s farmer, and cultivated the instant land to G, such as giving and receiving houses until the summer in 2005. Since then, the Plaintiff did not cultivate the instant land on the grounds of preparation for organic agriculture, aggravation of health, etc.) on November 5, 2007.