The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Basic facts

A. On September 14, 2002, the Plaintiff reported the income tax amount of stock transfer, acquired 6,500 shares of C Incorporated Partnership Co., Ltd., an unlisted corporation in B (hereinafter “instant corporation”) (hereinafter “instant shares”) and held office as the representative director of the instant corporation from the same date until August 11, 2004 and from December 6, 2004 to November 27, 2006.

From April 2, 2008, the Plaintiff’s Schedule D served as the representative director of the instant corporation. On September 2, 2011, the Plaintiff transferred all of the instant 65,000 shares to D in total at KRW 65,000 per share of KRW 10,000 (hereinafter “instant stock transfer contract”). On December 20, 201, the Plaintiff reported KRW 0,000,000, which is calculated by making the transfer income tax base preliminary return to the head of tax office of Franpo on December 20, 201.

B. As a result of conducting a regular audit of the instant corporation by the head of the tax office having jurisdiction over disposition of capital gains tax and local income tax rectification disposition of the Defendant, the Plaintiff notified the Defendant of taxation data that the Plaintiff acquired the shares

Accordingly, the Defendant denied the transfer value reported by the Plaintiff on the ground that the transfer value of the instant shares is low price as it is subject to the avoidance of wrongful calculation, and assessed the value per share as 62,193 won according to the supplementary evaluation methods under Article 63 of the Inheritance Tax and Gift Tax Act and Article 54 of the Enforcement Decree of the same Act, and notified the Plaintiff of the pre-announcement of taxation on July 5, 2013, by calculating the market value of the transfer value of the instant shares as 404,254,50 won (6,500 won per share 62,193 won x 6,500 won), and notified the Plaintiff of the pre-announcement of taxation on September 5, 2013 (hereinafter “instant disposition”).

C. On July 16, 2013, the Plaintiff notified the rescission of the instant share transfer contract to D, due to the nonperformance of the acquisition price.