2. The costs of lawsuit shall be borne by the Plaintiff.

A. On May 21, 2004, the Plaintiff completed the registration of ownership transfer on the ground of gift on May 14, 2004 with respect to the land of 1,874 square meters in Seodong-gu, Seodong-gu, Chungcheongnam-gu, Seoul, which was owned by B on May 21, 2004 and 1,077 square meters in D (hereinafter collectively referred to as “the previous land”). On January 17, 2012, the Plaintiff completed the registration of ownership transfer on the previous land on November 24, 201.

B. Meanwhile, on October 29, 2012, the Plaintiff completed the registration of ownership transfer in the Plaintiff’s future, on the ground of sale on September 18, 2012, with respect to the land substitution registration of 3,355 square meters (hereinafter “instant substitute land”) in Cheongju-si, Cheongju-si, G 3,355 square meters (hereinafter “H 3443 square meters”) (hereinafter “instant substitute land”).

C. The plaintiff A.

With respect to the transfer of the previous land as described in paragraph (1), the transfer income tax for the year 2012 was reported by applying the provisions on reduction and exemption of transfer income tax for farmland substitute land under Article 70 of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015; hereinafter the same), however, the Defendant deemed that the Plaintiff was not a direct farmer of the instant substitute land, thereby excluding the application of the said reduction and exemption provisions, and on April 1, 2016, notified the Plaintiff of the correction of the transfer income tax of KRW 143,860,000 (including additional tax) for the transfer income tax

(hereinafter "Disposition in this case"). / [Grounds for recognition] The entry in Gap evidence 1, 9, and Eul evidence 1 and 7 (including each number; hereinafter the same shall apply) and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff asserted that the Plaintiff directly cultivated the said substitute farmland for not less than three years, including the Plaintiff’s acquisition of the instant substitute farmland from 2013 to 2015, with the exception of having I perform the work of using some agricultural machinery from 2013 to 2015, such as water lender, fluor, water spaculate, fertilizer cycle, crop spraying, etc., and thus, the instant substitute farmland constitutes the substitute farmland subject to reduction of capital gains tax on substitute land.

Therefore, it is true.