1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On July 24, 1971, the Plaintiff completed the registration of ownership transfer under the Act on Special Measures for the Registration of Real Estate with respect to D forest land 14,083 square meters (hereinafter “C”) owned by the Plaintiff on July 24, 1971. The Plaintiff completed the registration of ownership transfer under the Act on Special Measures for the Registration of Real Estate with respect to the said land. On February 28, 1998, H forest 2,128 square meters and 403 square meters of I forest 403 square meters were divided from the said land on March 21, 2001, and D forest 11,52 square meters were divided, and thereafter, D forest 11,522 square meters was changed on November 1, 201.

B. On the other hand, on July 24, 1971, the Plaintiff completed the registration of ownership transfer on October 20, 1961 with respect to J Forest No. 4,383 square meters.

(hereinafter referred to as the “each of the instant lands” by aggregating 11,522 square meters and J-forest 4,383 square meters.

On September 30, 2011, the Plaintiff asserted that the transfer of each of the instant land to K Co., Ltd. (total transfer value of KRW 1,398,090,000, total acquisition value of KRW 330,632,840, Nov. 30, 201) constituted farmland for which each of the instant land was cultivated directly for at least eight years, while filing a preliminary return on capital gains tax base with the Defendant on November 30, 2011, and filed an application for capital gains tax reduction under the Restriction of Special Taxation Act.

In the register of land register, with respect to D land, the plaintiff completed the registration of ownership transfer for L (the representative director of K K) on May 21, 2012 due to sale on March 28, 2012, and with respect to J land, the plaintiff was registered as K corporation on May 21, 2012, and the registration of ownership transfer for sale on April 27, 2012.

The Defendant excluded capital gains tax reduction or exemption on the ground that the Plaintiff cannot be deemed to have cultivated each of the instant land directly for at least eight years, and imposed capital gains tax and additional tax on May 15, 2012 on the Plaintiff, including KRW 209,690,000,000.

(hereinafter “instant disposition”) e.

Accordingly, the plaintiff filed a request for review with the Board of Audit and Inspection on August 17, 2012, but the Board of Audit and Inspection filed a request for review on the same ground as in May 8, 2013.