1. All of the plaintiffs' claims are dismissed.

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

1. Details of the disposition;

A. On July 29, 1997, Plaintiff A acquired 1/2 shares in each of the 3,078 square meters and 1,330 square meters in Gangseo-gu Busan Metropolitan City (hereinafter “instant land”) and transferred the same on August 5, 2016, and filed a return on capital gains tax by applying the provision on reduction or exemption for self-Cultivating farmland for at least eight years under Article 69 of the Restriction of Special Taxation Act (amended by Act No. 14390, Dec. 20, 2016; hereinafter the same).

B. On September 4, 2017, the Defendant issued a revised notice of KRW 236,395,430, respectively (including additional tax) for the transfer income tax reverted to 2016 on the ground that “the Plaintiff cannot be deemed to have cultivated the instant land directly.”

hereinafter referred to as "disposition of this case"

(c) The Plaintiff appealed and filed a request for review with the National Tax Service on March 13, 2018, upon filing an objection on December 1, 2017. However, on September 13, 2018, a ruling dismissing the Plaintiff’s request was issued on September 13, 2018. [Grounds for Recognition] The Plaintiff did not dispute, A’s evidence 1, 2, and 5 (including the serial number; hereinafter the same shall apply).

written evidence Nos. 1, 2, 3, and 8, and the purport of the whole pleadings

2. Whether the disposition is lawful;

A. Although the plaintiffs' assertion directly cultivated the land of this case for eight years, the disposition of this case, which was made on a different premise, is unlawful as it misleads the facts.

B. (1) Determination (1) Article 69(1) of the Restriction of Special Taxation Act provides that “The tax amount equivalent to 100/100 of capital gains tax shall be reduced or exempted on the income accruing from the transfer of land prescribed by Presidential Decree, among the land cultivated directly by a resident prescribed by Presidential Decree who resides in the seat of farmland for at least eight years by the method prescribed by Presidential Decree.” Article 66(13) of the Enforcement Decree of the same Act (amended by Presidential Decree No. 27848, Feb. 7, 2017) provides that “Direct farming by the method prescribed by Presidential Decree” in the main sentence of Article 69(1) of the Act means that a resident