The Plaintiff owned 1/2 shares in the Seoul Gangnam-gu land (hereinafter “instant land”) and 37.1 shares in the building on its ground (hereinafter “instant building”), 37.2 shares in C, D, E, F and G, and 118.32 shares in H (hereinafter “the Plaintiff’s ownership part of the instant land and buildings”) and 118.32 shares in H, and 1/2 shares in the instant real estate; 1/2 shares in the instant land; 1/2 shares in the Plaintiff’s father; 70.1 shares in the underground floor, J, K, L, M and G among the instant building; 1/2 shares in the instant land; 70.2 shares in the underground floor, 187.68 shares in H among the instant building (hereinafter “the part of the instant land and buildings”).

On September 16, 2014, the Plaintiff transferred the instant real estate at KRW 4.5 billion to N andO (hereinafter “transferees”), and I transferred the instant real estate at KRW 6.5 billion to the transferee on the same day.

Then, the Plaintiff reported and paid the transfer income tax to the Defendant with the transfer value of the instant real estate as KRW 4.5 billion. However, as indicated below, the Defendant divided the transfer value of the instant land and the instant building in proportion to the standard market price ratio between the entire land purchase price and the entire building purchase price as indicated in the table below. Furthermore, the Plaintiff’s shares and the transfer value of the instant real estate are divided according to the standard market price ratio, and the transfer value of the Plaintiff’s shares and I’s shares as KRW 5,417,359,409, and was deemed as KRW 317,694,050, the transfer income tax of the instant real estate reverted to the Plaintiff on July 12,

(hereinafter “Disposition”). Separately owned area (unit: unit: unit: 159,104, 5701 floor on May 34, 207; 322.35, 322.35,910, 459, 456, 420, 850, 721, 272, 6164, 721, 2721, 272, 61, 272, 616 and 234.60-4, 202.4-293,285, 236 - 159, 104, 570, 107, 204, 108, 381, 378, 384, 197, 385, 284, 207, 204, 207.