2. The costs of the lawsuit are assessed against the defendant.

A. The Plaintiff is running a brokerage business with the trade name “C Licensed Real Estate Agent Office” in Gwanak-gu in Seoul Special Metropolitan City after registering the establishment of the Defendant.

B. On April 3, 2013, the Plaintiff affixed a seal on the broker column of the sales contract on the land and building located in Yeongdeungpo-gu Seoul Metropolitan Government (hereinafter “instant real estate”) (hereinafter “instant sales contract”).

The sales contract of this case states that E and F shall sell the real estate of this case to G in KRW 1.9 billion (land KRW 833 billion, KRW 1.67 billion), but in fact, the purchase price of the real estate of this case was KRW 2.75 billion.

C. On May 20, 2013, the Plaintiff reported the instant real estate transaction contract to the head of Yeongdeungpo-gu Seoul Metropolitan Government and received KRW 1 million each from the parties E and G of the sales contract.

On March 31, 2016, the Defendant rendered a disposition to suspend business operations for three months (from April 1, 2016 to June 30, 2016) by applying Articles 25(3), 26(1), and 39(1)6 and 8 of the former Business Affairs of Licensed Real Estate Agents and Report of Real Estate Transactions Act (Amended by Act No. 11866, Jun. 4, 2013; hereinafter “Licensed Real Estate Agents Act”) to the Plaintiff on the ground that “an improper preparation of a transaction contract and a description of confirmation of the object of brokerage are not issued.”

(hereinafter “instant disposition”). The Plaintiff was imposed an administrative fine of KRW 165 million on the ground that he/she filed a false report on real estate transactions by the head of Yeongdeungpo-gu Seoul Metropolitan Government.

[Ground of recognition] Facts without dispute, Gap's 1 through 5, Gap's 7 through 9 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. Before the Plaintiff’s assertion affixed a seal to the instant sales contract, the seller and the buyer of the instant real estate already agreed to enter into a sales contract, and the Plaintiff.