양도소득세부과처분취소
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
1. The reasons for the court's explanation concerning this case are as follows: 4, 5, 6, 7, 7, 7 and 7 of the judgment of the court of first instance are as follows; 5, 100,000 won, 10,000 won, 10,000 won, 5, 7, and 5, 7, respectively, shall be changed to "10,000,000", 10,000 won, 10,000 in the judgment of the court of first instance as "the exclusion period for imposition"; 10,000,000 won in the judgment of the court of first instance as "the exclusion period for imposition", and 10,000 won in the judgment of the court of first instance shall be added to "the related Acts and subordinate statutes" of the 10th judgment after the 9th judgment as "the related Acts and subordinate statutes" of the 4th judgment of the court of first instance.
2. The Plaintiff asserts to the effect that the actual transaction price at the time of acquisition of the Plaintiff’s key land cannot be recognized or confirmed by books or other evidentiary documents, and thus, the Plaintiff’s tax base and tax amount should be determined by making an estimated investigation according to the conversion price pursuant to Article 114(7) of the Income Tax Act. However, as seen earlier, it is reasonable to deem the actual transaction price at the time of acquisition of the Plaintiff’s key land as KRW 798 million. As such, the Plaintiff’s above assertion based on the premise that it is impossible to recognize or confirm the actual transaction price
3. In conclusion, the plaintiff's claim of this case is dismissed as it is without merit, and the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.