1. The plaintiff's claim is dismissed.

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

1. (i) The Plaintiff filed an application for full reduction or exemption of capital gains tax on the ground that the Plaintiff constitutes farmland for eight years, when filing a report on capital gains tax on February 17, 2012 to November 7, 2012, on December 31, 2012, on the following grounds: (i) the Plaintiff, who acquired the instant land in sequence from March 9, 2002 to March 19, 2003, transferred the aggregate of 1,478.3 square meters (hereinafter “instant land”).

D. On October 6, 2015, on the ground that the Plaintiff failed to meet the requirements for farmland for eight (8) years, the capital gains tax reduction or exemption, the Defendant stated that: (a) a written resolution on the determination of capital gains tax (Evidence 2) and a written notification on the determination of capital gains tax (proof 41,259,586,383 won, additional tax for failure to file a return of KRW 41,586,383, additional tax for failure to file a return of KRW 157,37) for the year 2012, the Defendant imposed capital gains tax of KRW 203,190,890 for capital gains tax of KRW 203,727,480 for the purpose of this case; (b) however, it is unclear whether the tax amount imposed by both the Plaintiff and the Defendant in this case after the correction or disposition was made.

The instant disposition that corrected and imposed B was made.

Article 22(1) of the Tax Tribunal Act provides that the Plaintiff shall be subject to the disposition of the instant case, and the Plaintiff shall be subject to the disposition of the said case, and the Tax Tribunal dismissed the said appeal on May 19, 2016.

【Facts without dispute over the grounds for recognition, Gap evidence 1, Eul evidence 1, 2, the purport of the whole pleadings

2. (i) In order to constitute farmland subject to reduction of or exemption from the total transfer income tax under Article 69 of the Restriction of Special Taxation Act and Article 66 of the Enforcement Decree of the Restriction of Special Taxation Act, the relevant land shall be farmland as of the date of transfer (if the purchaser changes the form and quality, starts construction works, etc. in accordance with the terms and conditions of a sales contract before the date of transfer, it shall be farmland as of the date of the sales contract) and farmland directly owned by the purchaser for eight