The costs of appeal are assessed against the defendant.

With respect to No. 1:

According to the reasoning of the judgment below, the court below concluded a mutual savings agreement with the above 20 billion won for the above 10-year loan and issued 600,000 won for the above 20-year loan to the non-party 60-year loan and the above 10-year loan transfer registration for the above 20-year loan for the purpose of the above 1-year loan transfer registration. The plaintiff did not pay 700,000 won for the above 6-year loan and 1560,000 won for the above 7-year loan and 1-60,000 won for the above 6-year loan transfer registration to the non-party 40-year loan, and the above 6-year loan transfer registration for the purpose of the above 1-year loan and 1-600,000 won for the above 6-year loan and 1-60,000 won for the above 6-year loan and 1-6,000 won for the above 2-year loan.

With respect to the second ground:

The gist of the grounds of appeal is that the current Enforcement Decree of the Income Tax Act was enacted on December 31, 1974, and Article 8 of the Addenda of the same Decree provides that "any income imposed or to be imposed by the previous provisions at the time of enforcement of this Decree shall be governed by the previous precedents," and the above Enforcement Decree shall not apply mutatis mutandis to the transfer income of this case that occurred before the enforcement of this Decree, and there is an error in the application of Article 45 (1) and (2) of the Enforcement Decree of the same Act to this case. However, even after examining the judgment of the court below, the court below applied the Enforcement Decree at the time of this case as discussed in the

With respect to the third point:

According to the reasoning of the judgment of the court below, since the registration of transfer of ownership which has been completed in the future even though it was made from the plaintiff on the real estate in this case was conducted for the security of obligation, it is clear that the defendant's taxation was unlawful under the judgment that it is not "transfer" of taxable object under Article 2 subparagraph 2 of the Act on Special Measures for the Suppression of Real Estate Investment. Thus, the court below's conclusion that the real estate in this case does not constitute land exempt under Article 6 of the same Act or land subject to exemption from tax liability under Article 7 (1) of the same

Therefore, the appeal shall be dismissed and the costs of appeal shall be borne by the losing party. It is so decided as per Disposition by the assent of all participating Justices.

Justices Lee Jong-soo (Presiding Justice)