1. The plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. On October 4, 2002, the Plaintiffs transferred to F and G, and filed a transfer income tax report with the transfer value of KRW 605,000,00,000, on a piece of land of KRW 238 square meters, D large 44 square meters, and E large 33 square meters (hereinafter “instant land”).

B. On March 31, 2010, when Nonparty G, the purchaser of the instant land, transferred the instant land to Nonparty H, Nonparty G reported the acquisition value of the instant land at KRW 960,000,000, and the Plaintiffs notified the Defendants of the taxation data by underreporting the transfer value of the instant land. The Defendants corrected the transfer value of the instant land at KRW 960,000,000 and notified the Defendants of the taxation data. On December 6, 2012, the Defendants imposed each of the instant dispositions on Plaintiff B on December 3, 2012, each of the instant dispositions imposed capital gains tax of KRW 177,531,680 (including additional tax of KRW 114,67,487) for the transfer income tax of KRW 176,820,420 (including additional tax of KRW 114,118,149,149) for the Plaintiff B in 202.

C. On February 18, 2013, the Plaintiffs filed an appeal with the Tax Tribunal on each of the instant dispositions, but was dismissed on May 16, 2013.

【Ground of recognition】 The fact that there is no dispute, entry in Gap 1, 2, and Eul 1 (including each number), the purport of the whole pleadings

2. Determination on this safety defense

A. The Defendants’ assertion was initially filed with the Seoul Eastern District Court and was transferred to the Seoul Administrative Court on August 26, 2013. However, the Plaintiffs’ claim becomes effective as of August 26, 2013, after the lapse of 90 days from May 21, 2013 when the written ruling of the Tax Tribunal on each of the instant dispositions was served on the Plaintiffs. As such, the instant lawsuit filed after the lapse of 90 days from the date of delivery of the written ruling was unlawful.

B. In accordance with Article 8(2) of the Administrative Litigation Act and Article 40(1) of the Civil Procedure Act, a lawsuit brought to a court without jurisdiction shall be transferred to the competent court upon confirmation of the decision of transfer.