A. On April 9, 2004, the Plaintiff completed the registration of ownership transfer on the ground of a consultation division inheritance on February 16, 2004 with respect to B forest No. 27,967 square meters (hereinafter “instant land”). On December 23, 2004, the Plaintiff transferred the instant land to Nonparty C and D (hereinafter “instant transfer”), and on December 28, 2004, filed a preliminary return on the tax base of capital gains tax with the transfer value of the instant land at KRW 35,000,000 with the Defendant on December 28, 2004.

B. However, in the process that C and D sold the above land to a third party again, it was revealed that the Plaintiff sold the above land to C and D in the purchase price of KRW 800,000,000.

Accordingly, on January 1, 2014, the Defendant: (a) deemed the transfer value of the instant land as KRW 800,000,000; (b) served a notice of tax payment imposing a total of KRW 561,269,450 (i.e., capital gains tax of KRW 544,921,80 (i.e., additional dues of KRW 16,347,650) (hereinafter “instant disposition imposing capital gains tax”); and (c) imposed a tax payment notice imposing a total of KRW 56,126,940 (i.e., local income tax of KRW 54,492,180) (i.e., additional dues of KRW 1,634,760) on the local income tax of KRW 54,634,760).

C. The Plaintiff filed an objection with the Defendant, and the Defendant rendered a decision to dismiss the Plaintiff’s claim on April 1, 2014.

On April 29, 2014, the Plaintiff filed a request for review with the National Tax Service on April 29, 2014, but was dismissed on July 22, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 2 and 10 (including where there are branch numbers), Eul evidence 1 and 2, and the purport of the whole pleadings

2. The attachment to the relevant Acts and subordinate statutes shall be as follows;

3. Judgment on the Defendant’s main defense

A. The Defendant of this case’s disposition of imposing local income tax of this case has jurisdiction over the place of payment of income tax against the Plaintiff, seeking revocation of the disposition of imposing local income tax and its additional dues.