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 10, 2001, the Plaintiff acquired 327 square meters in B, 327 square meters in C, 327 square meters in D, and 1,732 square meters in total (hereinafter “instant land”). On December 31, 2013, the Plaintiff reported the transfer income tax on farmland by applying the reduction and exemption of income tax and the deduction for long-term possession of farmland for at least eight years under Article 69 of the Act on Special Cases concerning Taxation, on February 28, 2014.

B. From May 7, 2019, the Defendant: (a) investigated the transfer income tax on the Plaintiff from May 7, 2019; (b) deemed that the Plaintiff did not directly cultivate the instant land for at least eight years based on the results of the investigation; and (c) notified the Plaintiff on May 16, 2019 of the rectification of the income tax of KRW 191,886,370 (including penalty tax) on the transfer income accrued to the Plaintiff for the year 2013 (hereinafter “instant disposition”).

On August 1, 2019, the Plaintiff was dissatisfied with the instant disposition and requested for adjudication on August 1, 2019, but the Tax Tribunal dismissed the Plaintiff’s request on November 27, 2019.

[Ground for recognition] Unsatisfy, Gap evidence Nos. 1 and 2, Gap evidence Nos. 3-1, 2, 3, Eul evidence Nos. 1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The gist of the Plaintiff’s assertion was as follows: (a) the Plaintiff was growing rice shed and dry field farming shed from the Plaintiff’s birth time to the Plaintiff’s birth time at 2,00 square meters and 3,000 square meters around F, 500 square meters and 3,000 square meters from other persons; (b) the Plaintiff cultivated all the Plaintiff’s instant paddy field after the Plaintiff died due to a traffic accident around April 1990; and (c) began to cultivate the instant land with other paddy fields after acquiring the instant land additionally around September 2001 (i) from around January 2006; (b) from around January 2009, F had been growing from the instant land to the point of view of expropriation; (c) from around 2006, f, from around 2006, f, rice farming shed and dry field farming shed; and (d) on April 3, 2009, f, f, from the instant land acquisition to the Plaintiff.