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

A. B transferred KRW 965,500,000 to Nonparty D, on March 29, 2015, KRW 367,320 of the capital gains tax on August 31, 2015, and paid KRW 367,320.

B. After that, around December 4, 2015, the Plaintiff assessed B as three housing owners per household, and notified the Plaintiff to pay capital gains tax of KRW 168,393,580 additionally imposed by December 31, 2015.

(hereinafter referred to as “instant taxation”). C.

In addition, B did not pay 46,260 won of comprehensive real estate holding tax in 2015.

However, at the time of the transfer of the instant real estate, B did not have three houses per household.

E. Meanwhile, B, as indicated in the attached list, remitted each of the following to the Defendant, who is his/her father, KRW 24 million on July 1, 2015, and KRW 17,088,00 on July 2, 2015.

[Reasons for Recognition] Facts without dispute, Gap 1 to 6 evidence, Eul 1 to 3, 8, 9 evidence (including additional evidence attached) and the purport of the whole pleadings

2. Determination

A. Even if an administrative disposition against the Plaintiff’s assertion is unlawful, the validity of the disposition cannot be denied unless the disposition is revoked by the process of administrative action, unless the disposition is revoked by the process of administrative action, unless there exist grounds that the defect is deemed null and void due to significant and apparent defects.

However, since the period of filing a lawsuit for cancellation of the instant taxation disposition was exceeded, the Plaintiff’s claim for the instant capital gains tax against B was effective.

Therefore, B, who was in excess of the obligation, is the defendant.

Since donation of cash, such as paragraph (1), constitutes a fraudulent act, it is revoked, and it is claimed to pay the amount stated in the purport of the claim against the defendant as compensation for value.

B. Even if, as alleged by the Plaintiff, the instant transfer income tax claim is effective on the Plaintiff based on the process of administrative action, as otherwise alleged by the Plaintiff, B did not constitute three houses per household at the time of transferring the instant real estate.