1.The judgment of the first instance shall be modified as follows:

The amount of KRW 202,00,000, which was concluded on April 23, 2012 between Defendant and B.

1. Basic facts

A. The Defendant’s husband B, on October 12, 2002, lent the name of his mother C, and purchased a 205.1mm2 in the name of Guri-si, Dori-si, 205.1m2, and completed the registration of ownership transfer on November 25, 2002. On August 26, 2003, the Plaintiff newly constructed three-story houses on that ground and completed the registration of ownership transfer under C’s name (hereinafter “the instant real estate”).

(2) On September 7, 2010, B entered into a contract to sell the instant real estate to E, China, for KRW 1,350,000,00,000, and on the same day, the registration of transfer of the instant real estate under the above title was completed as the registration office of Dong-ri District Court received 17909, but did not report and pay the transfer income tax on the transfer of the instant real estate.

3) On July 2, 2012, the head of the Gu-affiliated Tax Office under the Plaintiff-affiliated Tax Office shall notify the Plaintiff to pay KRW 251,653,570,00 not paid capital gains tax on the instant real estate by July 31, 2012 (hereinafter “instant notice”).

However, B did not pay the transfer income tax by the date of the closing of argument in this case, and the sum of the transfer income tax and its additional tax as of January 10, 2014 as stated in Table 1 below is 310,540,450 won.

The tax amount notified as of the date of notification of the statutory due date of the date when the tax liability to revert the items of taxation comes into existence shall be the capital gains tax of the delinquent amount of tax notified as of September 30, 2010;

B. B’s act of paying money to the Defendant in B is 1,086m2.3m2 (hereinafter “F land”) holding his own ownership on March 22, 2012.

(2) On April 2, 2012, G entered into a contract to sell KRW 424,00,000, and on the same day, G completed the registration of ownership transfer under the name of G as the receipt of 17569 by the Jeonju District Court Gunsan Branch. On the same day, G transferred KRW 203,686,394 to B’s account (new bank H) in the balance of the purchase price on the same day. (2) B transfers KRW 202,00,000 in the face value from the above account.