A. On June 23, 198, the Plaintiff acquired and transferred 1) The Plaintiff from his father B on June 23, 198, the Yeonsu-gu Incheon Dong Cdong (hereinafter “Cdong”).

D) 972 square meters (hereinafter “D land before subdivision”)

(2) Around 1996, D land owned by the Plaintiff was divided into D 947 square meters and E 25 square meters, and F 552 square meters prior to B’s ownership (hereinafter “F land before division”) into F 77 square meters and 445 square meters prior to G.

(3) On December 30, 1998, the Plaintiff acquired 77m2 from F, F, and F, as gifted from B (hereinafter referred to as “instant partition”) on December 30, 1998, the Plaintiff’s acquisition of the instant land by adding the Plaintiff’s acquisition of D, 972m2, among D land before subdivision, to “the instant acquisition”.

(4) On December 10, 2010, the Plaintiff transferred D 947 square meters and 77 square meters prior to F, to Nonparty H Co., Ltd.

(hereinafter “transfer of this case”). (b) The transfer of this case

On February 28, 2011, the Plaintiff made a preliminary return and payment of capital gains tax of 339,053,770 won by applying the special deduction for long-term possession on the transfer of this case to the Defendant. However, the Defendant deemed that the land subject to transfer falls under all non-business land, and determined and notified the Plaintiff on April 26, 2016, by excluding the special deduction for long-term possession, as income tax of 252,940,329 (including additional tax) for capital gains tax of 2010 for the Plaintiff on April 26, 2016.

(3) The Plaintiff is dissatisfied with the initial disposition and filed an objection with the Defendant on July 21, 2016. On August 25, 2016, the Defendant is affiliated with the third general residential area in accordance with the National Land Planning and Utilization Act (hereinafter “National Land Planning Act”). The part of the area of 343 square meters out of the area of 947 square meters in D 947 square meters in size (hereinafter “National Land Planning Act”).

(1) As to the above portion of land for non-business use, the special deduction for long-term possession was applied to reduce 85,583,673 won during the original disposition, and the remainder of the objection is dismissed (=252,940,329 won - 85,583,673 won).