1. The plaintiff's claim is dismissed.

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

1. Details of disposition;

A. On May 27, 2004, the Plaintiff acquired the unregistered buildings such as B factory site B 3,033 square meters and its ground factory building 784.8 square meters (hereinafter “instant factory”), warehouses, dormitories, etc. (hereinafter “the instant unregistered buildings”), machinery and equipment, wastewater treatment facilities, and water and water charging facilities (hereinafter “instant facilities”) in the auction procedure for real estate rent C with the Government District Court’s Seoul District Court’s proceeds of KRW 813,200,000.

B. On March 20, 2008, the Plaintiff decided to transfer 1,100 tons of the instant plant, unregistered buildings, and facilities to D with wastewater discharge facilities (hereinafter “wastewater right”) in total at KRW 1,200,000,000. On March 28, 2008, the Plaintiff completed the registration of transfer of ownership with respect to the instant plant on March 28, 2008. On May 11, 2009, the Plaintiff submitted to the Defendant a report on the tax base of capital gains tax and an agency for direct payment of capital gains tax, submitted to the Defendant on May 11, 2009, the Plaintiff changed the content of the instant contract to divide the wastewater right between D and D into KRW 400,000,000, the remainder of the instant factory and unregistered building except for the instant facilities subject to non-taxation into KRW 813,000,000,000.

C. On September 5, 2011, the Defendant: (a) determined the acquisition value by converting the appraised value at the time of the remaining assets except for the goods subject to non-taxation, among the proceeds from sale paid by the Plaintiff in the auction procedure for real estate rent, into KRW 502,368,00; and (b) determined the acquisition value by converting the said factory price of KRW 800,000,000 in the transfer value under the sales contract on the instant factory and unregistered buildings, facilities and right to wastewater; and (c) determined the transfer value of KRW 850,40,402,00 in the amount calculated by converting the unregistered building price of KRW 50,40 in the transfer value of KRW 42,382,280 in the necessary expenses by deducting gains from transfer; and (d) determined and notified the Plaintiff of KRW 116,491,910 in the capital gains tax, following the special deduction for long-term possession

(hereinafter “instant disposition”). D.

The plaintiff filed an objection and filed a request for examination against it, but on February 9, 2012.