1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance, which cited the reasoning of the judgment, is the same as that of the judgment of the court of first instance, except for a dismissal or addition as stated in paragraph (2). Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure

(hereinafter the meaning of the language used in this context is the same as that of the judgment of the court of first instance). 2. 5. The phrase " July 5, 2016" in the second 5 line is read as " July 25, 2016."

At the bottom of 2, 5 and 6 lines “The Defendant filed an application for rectification of KRW 40,331,460 of capital gains tax on the tax base and tax amount reported by the previous return of capital gains tax, and filed an application for a refund of KRW 40,331,460 of capital gains tax overpaid.”

At the bottom of the two pages, the part “satis” of 4 lines shall be raised to “satis”.

3. The number of pages 7 and 10 shall be as follows:

“A. The Plaintiff’s assertion 1) In addition to Article 60(3) of the Inheritance Tax and Gift Tax Act and Article 49(2) of the Enforcement Decree of the same Act, it is necessary to view the appraisal price by retroactive appraisal as the actual transaction price even according to the instant provisions on the computation of transfer value

Therefore, the transfer value of the real estate of this case should be calculated proportionally according to the appraisal result of this case, not the standard market price.

With respect to the calculation method of the transfer value, the standard market price is borrowed from the public disclosure price that is different from the actual transaction price, so unreasonable and unfair while the appraisal price is reasonable and fair.

However, where the classification of the value of land, buildings, etc. is unclear, the evaluation period of the appraisal value, which is the basis for calculating the transfer value, is limited to "the evaluation period of the appraisal value" from the commencement date of the taxable period immediately preceding the taxable period to

As such, the provision of this case goes beyond the evaluation period by arbitrarily limiting it.