A. On December 24, 2003, the Plaintiff acquired the instant real estate from Pyeongtaek-si C and its ground buildings (hereinafter collectively referred to as “instant real estate”), and completed the registration of ownership transfer on the same day (hereinafter referred to as “the instant registration of ownership transfer”) on the same date, and on April 30, 2014, transferred the instant real estate to D in KRW 2,200,000 (hereinafter referred to as “the instant acquisition and transfer”), and on June 25, 2014, filed a preliminary return on June 25, 2014 with the Defendant’s acquisition value at KRW 2,214,657,104, transfer value at KRW 2,20,000,000.

(The above reported acquisition value is the amount obtained by deducting the depreciation cost of 85,342,896 won recognized by the Plaintiff from the actual transaction value of 2,300,000,000 won at the time of the Plaintiff’s acquisition.

On July 6, 2016, the Defendant deemed that it is impossible to verify the actual transaction price at the time of the acquisition of the instant case, and determined and notified the Plaintiff of the increase in capital gains tax of KRW 244,254,200 (including additional tax) for the year 2016, by correcting the acquisition price as KRW 1,298,235,497, the conversion price; and

(hereinafter referred to as “the first disposition”). (c)

On July 13, 2016, the Plaintiff filed an appeal with the Tax Tribunal.

On November 28, 2016, the Tax Tribunal rendered a re-audit decision to the effect that the assessment standard and tax amount should be corrected by re-auditing the actual transaction price, etc. at the time of the acquisition of the instant case.

The Defendant issued a reinvestigation from January 20, 2017 to February 8, 2017 in accordance with the re-audit decision, and notified the Plaintiff on March 14, 2017 that the initial disposition is justifiable.

E. On March 27, 2017, the Plaintiff, who was dissatisfied with the notice of the results of reexamination, filed an appeal with the Tax Tribunal again.

On June 27, 2017, the Tax Tribunal decided that “The acquisition value of the instant real estate shall be KRW 1,519,416,828, the tax base and tax amount shall be corrected, and the remaining appeals shall be dismissed.”

F. The Defendant, July 17, 2017, shall be e.g.

The instant case is subject to the decision of the Tax Tribunal as described in the subsection.