1. Revocation of a judgment of the first instance;

2. The plaintiffs' claims are dismissed.

3. The costs of the lawsuit are assessed against the Plaintiffs.

1. Details of the disposition;

A. On February 17, 1997, the Plaintiffs reported and paid KRW 25,778,225 of the capital gains tax for March 7, 201, on the transfer of the instant land as KRW 300 million, the acquisition value of the instant land was KRW 128,895,000, the officially assessed individual land price (standard market price) in 1996, and the capital gains amount was KRW 118,723,500, the capital gains amount was KRW 118,723,500, and the capital gains amount was KRW 25,78,225,225, respectively, as of March 201, 201.

B. After that, on February 22, 2013, the Plaintiffs filed a request for correction to the effect that the Plaintiffs would refund KRW 5,587,103 on the ground that the date of acquisition of the instant land falls under February 17, 1997, by applying the officially assessed individual land price (1,530,000 square meters) in 197. However, the Defendant filed a request for correction to the effect that the refund would be made.

3. 27. Each rejected the Plaintiffs’ request for correction.

(hereinafter “each disposition of this case”). (c)

On April 4, 2013, the Plaintiffs were dissatisfied with each of the instant dispositions and filed an appeal with the Tax Tribunal. However, the Plaintiffs were dismissed on December 30, 2013.

[Reasons for Recognition] Unsatisfy, each entry in Gap evidence 1 through 6 (including each number), and the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The plaintiffs asserted that when the acquisition value is deducted from the necessary expenses for the return and payment of the transfer income tax of this case, the acquisition value was calculated by applying the standard market price in February 17, 1997, which was the time of acquisition of the land of this case, and the acquisition value was calculated by applying the standard market price in 1996, which was the immediately preceding year, pursuant to Article 164(3) of the Enforcement Decree of the Income Tax Act.

However, if the standard market price of the year is not publicly announced on the date of acquisition or transfer, there is an exceptional provision allowing the application of the standard market price of the immediately preceding year, and if the standard market price of the year of acquisition can be known at the time of return and payment of transfer income tax after the date.