1. The plaintiff's appeal is all dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. Basic facts

A. On October 13, 1978, the Plaintiff acquired a 27,570 square meters of B forest land (around October 13, 1978, the forest land was divided into C forest land and D forest land, etc., subject to several divisions procedures; hereinafter in this case, the above B forest land was referred to as “instant land”) and used it as an orchard, such as planting bamboo.

B. On June 8, 2012, the Plaintiff sold in total 3,906,689,500 won (land KRW 3,606,689,500, KRW 300,000, KRW 300,000) for the instant land and the instant land to a royalty Korea Co., Ltd., and received full payment of the purchase price on July 13, 2012.

C. On November 30, 2012, the Plaintiff calculated the transfer value of the instant land as KRW 3,606,689,500, the transfer income amount as KRW 3,500,182,651, and the calculated tax amount as KRW 925,219,407, respectively, and reported and paid KRW 725,219,40 as the transfer income tax for the instant land for the year 200,000, applying Article 69 of the Restriction of Special Taxation Act and Article 66 of the Enforcement Decree of the Restriction of Special Taxation Act for at least eight years as prescribed in Article 69 of the Enforcement Decree of the Restriction of Special Taxation Act.

The Plaintiff did not pay the transfer income tax accordingly on the ground that the Plaintiff’s sales value of pine trees was not subject to taxation.

E. On June 1, 2013, the head of the Kimhae Tax Office excluded self-employed farmland reduction and exemption on the ground that “the Plaintiff was confirmed to have cultivated the instant pine tree orchard using his family and figures, and the Plaintiff does not directly appear to have been for at least eight years on the instant land.” Accordingly, he issued a correction and notification to the Plaintiff to additionally pay KRW 210,980,000 (including additional tax 10,980,000,000,000,000,0000 as a capital gains tax for the year 2012 reverted to the nonperformance of payment).

(f) On September 1, 2013, the head of Kimhae Tax Office: (a) the transaction value on the real estate register of the instant land is KRW 3,906,689,500; and (b) the transfer value of the instant land is KRW 3,906,689,50, while the Plaintiff transferred the instant land and the instant land collectively, 300,000,000.