A. The Plaintiff is the mother of the deceased B (Death on January 12, 2012) and is the heir of B.

B. B on November 25, 2002, acquired 575.165/17 of 1757 of the Gangnam-gu Seoul Metropolitan Government 1,422 square meters (hereinafter “instant land or the instant land shares”) and on July 21, 2010, the instant land shares were expropriated in the Korea Land Corporation with a consultation on public land, but did not file a transfer income report.

C. The Defendant investigated B of the transfer income tax on the ground that it is impossible to verify the actual acquisition value of the instant land share on the ground that B was unable to verify the real acquisition value of the instant land share, and subsequently died, on December 6, 2012, the Defendant issued the instant disposition to determine and notify the Plaintiff, a heir of B, of the transfer income tax of 84,501,00 won (including additional tax of 14,198,031 won, additional tax of 13,510,846 won, and additional tax of 13,510,846 won for failure to report) for the year 2010.

On January 31, 2013, the Plaintiff filed an appeal with the Tax Tribunal on July 3, 2013 after filing an objection to the instant disposition. On January 6, 2014, the Tax Tribunal rendered a decision to re-examine the actual acquisition value of the instant land portion by ascertaining the sales contract for the instant land portion and the transfer value of D, the former owner, and D, the transfer value of the instant land, and the details and facts of the report on the transfer income tax on the portion transferred to G to G on November 11, 2013 by E, who jointly purchased the instant land, to the head of the F school conference, and accordingly, to rectify the tax base and tax amount.

E. After the above ruling, the Defendant maintained the instant disposition on February 18, 2014 after re-audit.

【Ground of recognition】 The fact that there has been no dispute, entry of Gap1-1, 1-2, 2-1, and 2-2, the purport of all pleadings and arguments

2. The gist of the Plaintiff’s assertion B is to purchase the instant land with Nonparty E with KRW 362 million and share purchase price with KRW 1/2,000,000 and to register the transfer of ownership by 1/2. However, the purchase price is paid with the public funds of the F church whose head is Nonparty E, and then the purchase price is paid with KRW 181 million later.