A. On December 6, 2001, the Plaintiff transferred to C on February 14, 2007, the general accommodation facilities (hereinafter “instant apartment complex”) with the size of 661 square meters in Suwon-si, which was acquired on December 6, 2001 and 661 square meters on the ground of reinforced concrete structure on the land (hereinafter “each of the instant real estate”), and reported and paid KRW 143,216,60 capital gains tax with the transfer value of KRW 4,420,000 with respect to the transfer of each of the instant real property as KRW 5,570,000 with the transfer value of KRW 5,570,000.

B. After conducting a tax investigation from July 7, 2010 to July 26, 2010, the director of the Central Regional Tax Office of China issued a notice to the Defendant on August 26, 2010 that “The Plaintiff received KRW 500,000,000 (hereinafter “the instant money”) from C at the time of the transfer of each of the instant real property from the Plaintiff, as the transfer price for the house and fixtures of the instant Moel, shall be included in the transfer price of each of the instant real property. The Plaintiff paid KRW 295,00,000 to the repair cost for each of the instant Moel prior to the transfer of each of the instant real property.”

C. On November 5, 2010, the Defendant issued a notice of KRW 440,372,090 to the Plaintiff on November 5, 2010.

On January 31, 2011, the Plaintiff lodged an appeal with the Tax Tribunal. On November 9, 201, the Tax Tribunal partially accepted the Plaintiff’s appeal and rendered a decision that “The Plaintiff paid KRW 295,000,000 to the Plaintiff for the repair work cost for the instant Mour, prior to the transfer of each real estate in this case, added the tax base and tax amount to necessary expenses, and subsequently corrected the tax base and tax amount.”

E. According to the above decision, on November 29, 201, the Defendant corrected the transfer income tax for the Plaintiff for the year 2007, as 303,851,870 won.

The imposition of capital gains tax of KRW 303,851,870, which was finally determined after the above correction, is "."