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

A. The Plaintiff, which acquired on December 28, 1971, transferred the value of the instant real estate to D on April 29, 2004 (hereinafter “the instant transfer”). On June 30, 2004, the Plaintiff reported the transfer of the instant real estate amount of KRW 390,00,000, calculated tax amount of KRW 54,536,514, amount of tax to be paid voluntarily, amount of tax to be paid voluntarily in KRW 49,082,863, and amount of tax to be paid voluntarily in 2004 (hereinafter “instant report”).

B. From May 1, 2013 to 19th of the same month, the Defendant investigated the difference between the transfer value of the instant real estate reported by the Plaintiff and D from May 1, 2012, and confirmed the actual transfer value of the instant real estate at the time of the instant transfer as KRW 710,00,00,000; and on July 4, 2013, deeming the acquisition value as KRW 204,174,924, which is the conversion value based on the standard market price at the time of the acquisition, as KRW 348,563,406, which is the conversion value based on the standard market price at the time of the Plaintiff’s acquisition as KRW 348,563,406, the total determination amount as KRW 171,603,098 (additional tax amount as KRW 113,782,826,826, and KRW 57,820,272,00 (hereinafter “instant”).

C. On October 2, 2013, the Plaintiff filed an objection with the commissioner of the Daegu Regional Tax Office against the instant disposition, and dismissed the objection, the Plaintiff filed an appeal with the Tax Tribunal on December 26, 2013, and the Tax Tribunal dismissed the appeal on November 6, 2014.

[Ground of recognition] The fact that there is no dispute, Gap 1, 8, 9, Eul 1 through 4, 9, 11, and 12, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion (1) Article 96(1)6 of the former Income Tax Act (amended by Act No. 7289 of Dec. 31, 2004; hereinafter “former Income Tax Act”) is the time and acquisition by the transferor.