1. The Defendant’s transfer income tax amounting to KRW 692,581,940 (including additional tax) for the Plaintiff on May 1, 2014.

1. Details of the disposition;

A. The Plaintiff acquired the right to sell a parcel of land C 738 square meters from Guri-si, Guri-si (hereinafter “instant sales right”), but transferred the right to sell a parcel of land to the Ansan Development Co., Ltd. on July 23, 2003 (hereinafter “Bri-si Development”).

B. On September 15, 2003, the Plaintiff calculated the transfer value of the sales right of this case to the Defendant as the actual transaction value of KRW 1.677 million, the acquisition value of KRW 1.777 billion, and the necessary expenses at KRW 0,000,000, and paid the transfer income tax by scheduled return.

C. On May 1, 2014, the Defendant corrected and notified the Plaintiff to additionally pay the transfer value of the instant sales right of KRW 2.787.5 million, the acquisition value of KRW 1.613 billion (i.e., KRW 236 million) (including additional tax of KRW 32,298,236, and additional tax of KRW 343,843,704) for the year 2003, premised on the premise that the transfer value of the instant sales right is KRW 1.63 billion (i.e., KRW 1., KRW 1.3777 billion), and KRW 692,581,940 for the transfer income tax for the year 2003, under the premise that it is KRW 0 as necessary expenses.

(hereinafter “instant disposition”) D.

The plaintiff was under the procedure of the previous trial.

[Ground of recognition] Facts without dispute, Gap 1, 3, 4 evidence, Eul 1 and 6 evidence, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The plaintiff's assertion that the defendant recognized the premium of KRW 236 million paid to the former owner B out of the acquisition price of the right to sell the instant land, but the plaintiff paid KRW 367 million to the former owner B at a premium of KRW 367 million, so the acquisition price is KRW 1.74 billion (=the sale price of KRW 1.377 billion).

In addition, since the plaintiff spent 70 million won as brokerage commission, 70 million won should be recognized as necessary expenses.

Therefore, the defendant's disposition of this case made on a different premise is unlawful.

B. Determination as to the assertion on acquisition value (whether the premium was caused by 367 million won) (1) the burden of proof as to the tax base that is the basis of taxation in a lawsuit seeking revocation of the disposition of income tax is against the tax authority, and the tax base shall be from the revenue.