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

A. On February 19, 2001, the registration of transfer of ownership was completed to C on January 2, 2004 on the ground of the successful bid due to voluntary auction with respect to the land and buildings on the Seo-gu Daejeon Special Metropolitan City B, Seo-gu 874.3 square meters and its ground (hereinafter collectively referred to as the “instant real estate”) and the registration of transfer of ownership was completed to E on October 4, 2007 on the ground of the registration of transfer of ownership, the registration of transfer of ownership, and the sale by compulsory auction.

B. On January 2, 2009, the director of the Seo-gu Daejeon District Tax Office imposed a disposition of KRW 328,870,760 on the Plaintiff for the acquisition value of the instant real estate as KRW 1,650,00,000 on the ground that “the Plaintiff made a title trust of the instant real estate to D” (including additional taxes; hereinafter the same shall apply) for the acquisition value of the instant real estate in 207.

C. On July 1, 2014, the Defendant issued an increase in the acquisition value of the instant real estate in KRW 1,411,100,000 on the ground that “the Plaintiff made a title trust of the instant real estate to C and D in succession” (hereinafter “instant disposition”) to the Plaintiff, thereby increasing the transfer income tax of KRW 186,791,230 for the year 2007 (hereinafter “instant disposition”).

[Ground of recognition] Facts without dispute, Eul evidence Nos. 1 through 4, Eul evidence No. 6-1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is unlawful for the following reasons.

1) The first argument that the capital gains tax may be imposed on C or D is not the owner of the instant real estate, but the transfer income tax may not be imposed on the Plaintiff. 2) The second argument that the extinctive prescription for the instant disposition expired for a period of 5 years, and C or D cannot be said to have concealed the instant real estate as its owner, and thus, the exclusion period of 10 years has expired from January 2, 2004, and C transferred the instant real estate to D.

(b) Entry in the attached Form of relevant Acts and subordinate statutes;

(c) Gap 1, 3 through 6, as to the first argument for judgment 1;