1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On September 20, 2012, the Plaintiff acquired a size of 307.6 square meters in Seo-gu Incheon, Seo-gu, Incheon on March 8, 2013, and newly built a reinforced concrete structure (refinite concrete roof), three-story houses, and a total of 459.25 square meters in multi-family houses and Class II neighborhood living facilities (hereinafter “instant building”).

B. On June 2, 2016, the Plaintiff transferred the said land and the instant building to C and D in KRW 1.97 million. On July 12, 2016, when filing a transfer income tax report on July 12, 2016, the acquisition value of the said land was KRW 4.6 million, which is the actual transaction value, and the acquisition value of the said building was KRW 743 million, which is the conversion value.

C. The Defendant deemed that the Plaintiff reported excessive acquisition value of the building of this case, and notified the Plaintiff of the total construction cost of KRW 350 million on the detailed statement of construction cost submitted to the competent authority at the time of filing a report on the establishment and registration of the building of this case as the actual transaction price.

Accordingly, the Plaintiff filed a request for pre-assessment review on December 4, 2017, and the Defendant, after the examination by the National Tax Examination Committee, conducted a re-assessment of the actual transaction price on the acquisition value of the building in this case and made a decision to correct the tax base and tax amount according to the result.

Accordingly, on May 2, 2018, the Defendant reviewed the acquisition value of the instant building and rendered a disposition imposing capital gains tax of KRW 63,233,880 to the Plaintiff on May 2, 2018 on the ground that the construction cost of KRW 447,00,000 is the actual transaction amount.

The disposition of this case is referred to as the "disposition of this case"

E) The Plaintiff appealed and filed an appeal with the Tax Tribunal on July 13, 2018, but received a decision of dismissal on November 16, 2018. [The purport of each of the entries and arguments in Gap, Gap, 1, 2, 3, 4, 7, Eul, and Eul, as well as Eul’s evidence Nos. 1 and 2.

2. Whether the disposition is lawful;

A. The plaintiff's assertion is that the plaintiff's construction cost is KRW 69 million paid to E, the electrical construction cost paid to F, KRW 3.2 million paid to G, KRW 45 million paid in cash, and the balcony expansion construction cost.