1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. On September 3, 1992, the Plaintiff: (a) sold the instant real estate at KRW 86,00,000 to C and D on April 22, 2011; and (b) completed the registration of ownership transfer on June 16, 201, each of 1/2 shares was sold to C and D on June 16, 201.

B. On December 10, 2013, the Defendant imposed capital gains tax and additional tax of KRW 22,400,000 on the Plaintiff, deducting the acquisition value of KRW 45,600,000 from the transfer value of KRW 86,00,00, necessary expenses, and special deduction for long-term holding, KRW 8,400,00 from the transfer value of KRW 86,60,000, and KRW 22,40,000 from the special deduction for long-term holding.

(hereinafter referred to as “instant disposition”). C.

The Plaintiff dissatisfied with the instant disposition and filed a request for examination with the Commissioner of the National Tax Service on April 11, 2014, but was dismissed on May 8, 2014.

【Ground of recognition】 The fact that there has been no dispute, Gap Nos. 1, 2, 3, 7, 9, 10 (including paper numbers, hereinafter the same shall apply), Eul Nos. 1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion not only spent at least KRW 65 million in total to transfer the instant real estate, but also paid at least KRW 65 million in light of the price increase in the period during which the Plaintiff owned the instant real estate on July 192, 192, as well as the repair work of the instant real estate, urban gas installation work, the replacement of gas distribution board, and the replacement of boiler.

Nevertheless, the instant disposition based on the premise that the transfer margin exists is unlawful.

B. It is as stated in the attached Form of the relevant statutes.

C. 1) First, as to the Plaintiff’s assertion on reflection of price inflation during the retention period of the instant real estate, the Health Unit and the former Income Tax Act (amended by Act No. 10625, May 2, 2011; hereinafter the same applies)

The price rise in the holding period of the instant real estate.