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

A. The Defendant: (a) purchased from the Plaintiff on February 17, 2006, KRW 72,793 square meters of K-based K-based K-based K-based K-based land in KRW 1,50,000,000 and performed civil engineering works, etc.; and (b) sold the instant land in KRW 3,10,000,000 from 207 to 2011, on the premise that the said land constitutes real estate sales business under Article 122 of the Enforcement Decree of the Income Tax Act.

B. Accordingly, on April 4, 2013, the Defendant imposed on the Plaintiff the global income tax of KRW 412,041,260, global income tax of KRW 152,938,980, global income tax of the year 2008, global income tax of KRW 1,484,693,080, global income tax of the year 2009, global income tax of KRW 115,474,060, global income tax of the year 201 (including each additional tax; hereinafter the “instant disposition”).

C. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on June 30, 2013, but the Tax Tribunal dismissed the Plaintiff’s appeal on November 15, 2013.

[Ground for Recognition: Facts without dispute, Gap evidence 2-1 through 4, Gap evidence 4-1, Gap evidence 5-1, purport of whole pleadings]

2. Whether the instant disposition is lawful

A. Plaintiff’s assertion 1) The Plaintiff merely performed the business of dividing and selling the land or providing other consulting services from co-owners of the instant land, and does not resell the instant land. The Defendant deemed the Plaintiff as a real estate sales broker who sold the instant land unregistered, and thus was unlawful. 2) Even if the Plaintiff engaged in real estate sales business, Article 64(2) of the former Income Tax Act (amended by Act No. 12738, Jun. 3, 2014) and Article 122(2) of the Enforcement Decree of the same Act provide that necessary expenses, etc. of transferred assets shall be deducted from the profit margin.