1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. On September 5, 2006, the Plaintiff completed the registration of transfer of ownership on September 4, 2006 with respect to the land of this case 14,310,572 won (hereinafter “the transfer income tax of this case”) with respect to the land of this case on November 30, 2006, after completing the registration of transfer of ownership on September 4, 2006 with respect to the land of this case.

B. As a result of the investigation of the tax offense against the Plaintiff by the director of the Central District Tax Office, the Defendant: (a) deemed that “the Plaintiff prepared a false land sales contract with B, trusted the instant land in title to B, and newly built and sold a building on the instant land under the name of B”; (b) on April 1, 2015, the Defendant imposed a notice on the Plaintiff at each of the global income tax of KRW 1,906,889,910, global income tax for the year 2007 (hereinafter “instant global income tax”); (c) global income tax for the year 2009, global income tax for the year 2009; and (d)87,715,680, global income tax for the year 2010.

C. On May 28, 2015, the Plaintiff filed a claim for correction to the Defendant that “the Defendant denied the transfer of the instant land to B and imposed a comprehensive income tax on the Plaintiff, and accordingly, the Plaintiff corrected the transfer income tax of this case on the ground of the Plaintiff’s transfer to B and sought a refund of the transfer income tax already paid.”

(hereinafter “instant request for correction”) D.

On July 23, 2015, the Defendant rendered a disposition to return the instant claim for correction against the Plaintiff on the ground that “the period for filing the instant claim for correction has expired pursuant to Article 45-2 of the Framework Act on National Taxes.”

(hereinafter “instant No. 1 Disposition”). (e)

The Plaintiff appealed and filed an appeal with the Tax Tribunal on September 15, 2015. On January 21, 2016, the Defendant dismissed the instant request for correction on the ground that “The capital gains tax of the instant case, which was paid by the Plaintiff, was treated as already paid tax from the global income tax for the year 2007, which was notified to the Plaintiff on April 30, 2015.”