1. The Defendant’s imposition of capital gains tax of KRW 221,942,890 against the Plaintiff on April 11, 2016, which belonged to the year 2010, is 210,874.

1. Details of the disposition;

A. On December 26, 1985, the Plaintiff acquired and retained B forest land No. 25,055 square meters, and owned them. On May 6, 2010, the Plaintiff divided 9,893 square meters of the above land into C among the above land (hereinafter “instant land”) on May 6, 2010, and completed the registration of transfer of ownership with respect to the instant land incorporated into the housing site development project in the Korea Land and Housing Corporation (hereinafter “Corporation”) on May 7, 2010.

B. On July 30, 2010, the Plaintiff filed an application for reduction of or exemption from capital gains tax on the ground that he directly cultivated the instant land for at least eight (8) years upon filing a preliminary return of tax base of capital gains tax on the instant land with the Defendant, but the Defendant, after undergoing a field investigation, cannot be deemed as farmland, and the Plaintiff’s land cannot be deemed as farmland for at least eight (8) years, on May 24, 201, determined and notified the Plaintiff of KRW 117,66,70 (including additional tax) of capital gains tax for the year 2010.

C. On August 22, 2011, the Plaintiff dissatisfied with the above disposition and received a request for review from the Board of Audit and Inspection on April 5, 2012, but received a request for dismissal on April 5, 2012. On June 29, 2012, the Plaintiff filed an administrative litigation to seek revocation of the above disposition (hereinafter “previous administrative litigation”) with this court (hereinafter “previous administrative litigation”) on June 29, 2012, but was ruled against the Plaintiff, but the appeal was dismissed in the second instance (Seoul High Court 2013Nu18027) and the judgment against the Plaintiff became final and conclusive.

On the other hand, on December 9, 201, the Plaintiff filed a lawsuit seeking compensation for damages against the Corporation (hereinafter “instant lawsuit”) on the ground that the land compensation (sale price) was under-calculated. On July 9, 2015, the Seoul High Court (2014Na2021319), which rendered a judgment ordering the Corporation to pay the Plaintiff KRW 560,75,316 (hereinafter “instant increase compensation”) of the shortage in land compensation, and the said judgment became final and conclusive, on July 27, 2015, that the Corporation shall pay the Plaintiff KRW 560,75,316 (hereinafter “instant increase compensation”).